Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $12,257 in petitioners' Federal income tax for 1982 and an addition to tax of $3,064 under section 6661(a).
The issues for decision are (1) whether petitioners are entitled to deduct their allocable share of partnership losses resulting from research and development expenditures and (2) whether petitioners are liable for the section 6661 addition to tax. Unless...
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