Whether income is exempt under Article 19 of the tax treaty between the People’s Republic of China and the United States; whether Taxpayer is entitled to unsubstantiated deductions; whether Taxpayer is entitled to a deduction for moneys repaid to family members; and whether Taxpayer is entitled to a deduction for moneys paid into her 401(k) account.
Contracting. Taxpayers assumed the prime contracting transaction privilege tax liabilities of the Off-site Contractors, who were not exempt subcontractors, by issuing Form 5005 exemption certificates to the Off-site Contractors.
Taxpayer was a prime contractor subject to the transaction privilege tax on his entire fees where he was hired as a “construction manager” or “advisor” to use his contracting knowledge to supervise or coordinate several construction projects, as well as doing some construction himself. Where Taxpayer was one of the persons on the title of the property on which he oversaw construction, he was liable for use tax on the items he purchased from retailers who knew him to be a contractor and did not include a charge for tax on the purchases.
Taxpayer not allowed research and development credit, under A.R.S. 43-1168, where the Taxpayer relies on unsubstantiated estimates of research expenditures from an acquired company in years preceding the acquisition of such company to calculate the credit.