Memorandum Findings of Fact and Opinion
PATE, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioner's 1988 and 1989 Federal corporate income taxes of $589 and $7,598, respectively. The sole issue for our decision is whether certain payments petitioner made during those years were for the acquisition of...
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