Memorandum Findings of Fact and Opinion
IRWIN, Judge:
The Commissioner determined a deficiency in petitioners' income tax of $1,397 for the year 1964. The issues left to be resolved are whether the sole proprietorship operated by petitioners was entitled to a deduction of $5,574.50 as an accrued expense for research to be performed for its customers, or, if not, whether $2,516.50 expended in 1964 for such research may be deducted in that year. Resolution...
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