MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent mailed to petitioner Jeffrey L. Rayden (petitioner), as tax matters partner, a notice of final partnership administrative adjustment for 1983 with respect to Digital Accounting Technology, Ltd. (DAT). After settlement by the parties, the only issue for decision is whether $904,268 in expenditures of DAT qualify as deductible research and development expenditures under section 174.
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