Legal Opinion

LDL Research & Development II, Ltd. v. Commissioner

Court of Appeals for the Tenth Circuit

Decided September 8, 1997No. 95-9014PublishedCited by 9 opinions

1Opinion of the Court

LUCERO, Circuit Judge.

Section 174(a) of the Internal Revenue Code allows “[a] taxpayer [to] treat research or experimental expenditures which are paid or incurred by him during the taxable year in connection with his trade or business as expenses which are not chargeable to capital account. The expenditures so treated shall be allowed as a deduction.” In this case we are required to determine when a partnership’s expenditures made to third parties to engage in research are “in connection with [the partnership’s] trade or business” and consequently deductible as current expenses pursuant to 26…

2Cases cited21 opinions

  1. Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
  2. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  3. Whipple v. CommissionerSupreme Court of the United States · 1963
  4. Snow v. CommissionerSupreme Court of the United States · 1974
  5. Bernard A. Levin, Phyllis Levin, Alan T. Hrabosky, and Delores Hrabosky v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987

16 more not listed; retrieve them via the Exa API.

3Cited by9 opinions

  1. Dill v. City of EdmondCourt of Appeals for the Tenth Circuit · 1998
  2. Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
  3. Clearmeadow Investments, LLC v. United StatesUnited States Court of Federal Claims · 2009
  4. Dill v. City Of EdmondCourt of Appeals for the Tenth Circuit · 1998
  5. Utah Jojoba I Research v. CommissionerUnited States Tax Court · 1998

4 more not listed; retrieve them via the Exa API.

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