LEWIN v. C.I.R.

No. 02-1169.

335 F.3d 345 (2003)

Nathan LEWIN, a partner other than the tax matters partner, Petitioner-Appellant, and I-Tech R & D Limited Partnership, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided March 26, 2003.


Attorney(s) appearing for the Case

ARGUED: Nathan Lewin, Lewin & Lewin, Washington, D.C., for Appellant. Rachel Ida Wollitzer, Tax Division, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Alyza D. Lewin, Lewin & Lewin, Washington, D.C., for Appellant. Eileen J. O'Connor, Assistant Attorney General, Thomas J. Clark, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.

Before GREGORY, Circuit Judge, GOODWIN, United States District Judge for the Southern District of West Virginia, sitting by designation, and MICHAEL, Senior United States District Judge for the Western District of Virginia, sitting by designation.


Affirmed by published PER CURIAM opinion.

OPINION

PER CURIAM.

Petitioner-Appellant Nathan Lewin appeals from the decision of the United States Tax Court holding that petitioner's deductions for research and development expenses do not satisfy the requirements of § 174(a)(1) of the Internal Revenue Code. Jurisdiction in this court is invoked pursuant to 26 U.S.C. § 7482. After carefully considering the record, the briefs, and the parties...

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