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SOFTWARE 16 v. COMMISSIONER

Docket No. 4812-88.

63 T.C.M. 2876 (1992)

T.C. Memo. 1992-247

Software 16, Herbert M. Kuschner, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed April 27, 1992.

Attorney(s) appearing for the Case

Larry Kars, for the petitioner. Elizabeth P. Flores and Stephen Ianello, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined an adjustment to the partnership return of Software 16 for the 1982 taxable year due to disallowance of deductions for research and experimental expenses in the amount of $648,890,1 $60,000 advertising expenses, and a $52,710 credit for research and experimental expenses.

After concessions, the issues presented for our consideration are: (1)...

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