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PALAEZ & SONS, INC. v. COMMISSIONER

Docket No. 18049-97.

114 T.C. 473 (2000)

PELAEZ AND SONS, INC., CHRISTINA P. HOOKER, TAX MATTERS PERSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 30, 2000.

Attorney(s) appearing for the Case

Philip A. Diamond and Daniel C. Johnson, for petitioner.

Charles A. Baer and James F. Kearney, for respondent.

GERBER, Judge:

Respondent issued a notice of final S corporation administrative adjustment (FSAA) for Pelaez & Sons, Inc.'s (corporation) taxable years ended September 30, 1992, 1993, and 1994, reflecting net adjustments in the amounts of $1,514,209, $46,148, and ($155,814), respectively. The question we consider is whether the corporation is required, under the provisions of section 263A,1 to capitalize developmental expenses...

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