Software Company Fights Expense Treatment, $147 Million Tax Bill

An affiliate of an Ohio-based software company is contesting an IRS adjustment of $147 million in income tax for the years 2020 and 2021, listing a litany of corporate expenses in dispute.

Universal Computer Systems Holding Inc. petitioned the US Tax Court May 2 after the IRS disallowed deductions for about $1 million in business aircraft expenses and $38.5 million in legal and professional fees. An IRS determination filed with the petition shows the government told the company it didn’t show the expenditures “constitute ordinary and necessary business expenses.”

Universal Computer Systems, which lists its “principal place of business” as ...