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KOONS v. COMMISSIONER

Docket No. 74965.

35 T.C. 1092 (1961)

JOHN F. KOONS AND M. E. KOONS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 31, 1961.

Attorney(s) appearing for the Case

C. Chester Guy, Esq., for the petitioners.

Henry T. Nicholas, Esq., for the respondent.

FISHER, Judge:

Respondent determined a deficiency in petitioners' income tax for the year 1955 in the amount of $10,991.04.

The sole issue presented for our consideration is whether expenditures made by petitioners in 1955 in the amount of $45,000 or any part thereof constituted research and experimental expenditures paid or incurred in connection with his trade or business within the intendment of section 174(a) (1) of the Code of 1954.

FINDINGS...

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