MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $57,301 deficiency in petitioners' 1991 Federal income tax, and an $11,460 section 6662(a) accuracy-related penalty for that year.
The issues for decision are (1) whether petitioners are entitled to deduct as research and development expenses $165,000 that Patrick F. Sheehy paid in 1991 to acquire interests in thoroughbred racehorses,
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