Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By a notice of deficiency dated February 21, 1984, respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1980 and 1981 in the amounts of $21,130.78 and $24,848.79, respectively.
The issues for decision are (1) whether petitioners were properly entitled to take deductions for research and development expenses and miscellaneous expenses resulting from their...
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