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SPELLMAN v. COMMISSIONER

Docket No. 24826-84.

52 T.C.M. 298 (1986)

T.C. Memo. 1986-403

Burton L. Spellman and Roslyn Spellman v. Commissioner.

United States Tax Court.

Filed August 27, 1986.

Attorney(s) appearing for the Case

Allen B. Glass, Morton Grove, Ill., for the petitioners. J. Anthony Hoefer, for the respondent.

Memorandum Opinion

KÖRNER, Judge:

This matter is before the Court on respondent's motion for partial summary judgment pursuant to the provisions of Rule 121.1 The issue raised by the motion is whether Elmer South Oil Partnership, Ltd., an Oklahoma limited partnership, is entitled to a deduction for research and experimental expenditures under section 174.2

Respondent determined a deficiency...

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