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MOORE v. COMMISSIONER

Docket No. 13672-84, 13872-84.

56 T.C.M. 1150 (1989)

T.C. Memo. 1989-38

Allan M. Moore and Joyce Moore v. Commissioner.

United States Tax Court.

Filed January 24, 1989.

Attorney(s) appearing for the Case

Martin N. Gelfand, Dennis L. Perez and Bruce I. Hochman, 9100 Wilshire Blvd., Beverly Hills, Calif., for petitioners. Joyce L. Sugawara, Benjamin Duncan and Bruce Neuling (specially recognized), for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

In notices of deficiency dated April 4, 1984, and March 6, 1984, respondent determined deficiencies in petitioners' income taxes for 1979 and 1980 of $17,350.17 and $32,430.80, respectively.1 This case was selected as a test case in order to resolve issues common to a large group of taxpayers who, during 1979 and 1980, claimed research and development expense deductions through...

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