Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined income tax deficiencies against petitioners for the years 1960 and 1962 in the respective amounts of $99.60 and $1,154.82. The only issue for decision is whether the petitioner, Jack Pershing Stanton, was engaged in a trade or business as an inventor so that certain expenditures pertaining to the construction of a "StormSafe" boat qualify for deductions as research and experimental...
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