Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a deficiency in petitioner's 1970 Federal income tax of $214.73.
The two issues for decision are: (1) whether certain research expenditures incurred by petitioner are deductible as business expenses, educational expenses or research expenses, and (2) whether such expenditures, if allowable, are deductible from gross income...
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