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expenses related to researching a topic in order to write a book,
without more, are “start-up expenditures” within the meaning of
section 195. Accordingly, we will sustain respondent’s
determination to disallow the miscellaneous deductions of $15,892
on Mr. Deward’s Schedule C relating to amortization and the
expenditures incurred for research for his book, including costs
for traveling to Europe.7 We will additionally sustain
respondent’s adjustment of petitioners’ medical expense
deductions and miscellaneous itemized deductions because of the
change in the determined amount of adjusted gross income.
To reflect the foregoing,
Decision will be entered
under Rule 155.
7 Although we disallow the deductions in issue here, we note
that a taxpayer may elect to treat start-up expenditures as
deferred expenses, deductible pro rata over a period of at least
60 months, beginning with the month in which the active trade or
business begins. Sec. 195(b)(1). We need not decide here
whether Mr. Deward’s travel expenditures qualify for this
treatment.
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Last modified: November 10, 2007