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AGENCY AUTOMATION PARTNERS, LTD. v. COMMISSIONER

Docket No. 30184-91.

68 T.C.M. 490 (1994)

T.C. Memo. 1994-411

Agency Automation Partners, Ltd., Shamrock Automation Systems, Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed August 22, 1994.

Attorney(s) appearing for the Case

Robert A. Pierce, Kevin J. Carroll, David J. Hull, and Carla A. Green, P.O. Box. 391, Tallahassee, Fla., for the petitioner. William R. McCants, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

In a Notice of Final Partnership Administrative Adjustment (FPAA) issued by respondent with respect to Agency Automation Partners, Ltd. (the partnership), for the taxable year ending December 31, 1983, respondent determined that the partnership is not entitled to deductions in the amounts of $149,837 claimed as a legal expense, $60,000 claimed as an administrative expense, and $3.6 million for research...

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