SNOW v. COMMISSIONER

Docket No. 7125-70.

58 T.C. 585 (1972)

EDWIN A. SNOW AND HELEN B. SNOW, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 30, 1972.


Attorney(s) appearing for the Case

Harold W. Walker and Burgess L. Doan, for the petitioners.

Rudolf L. Jansen, for the respondent.


BRUCE, Judge:

Respondent determined a deficiency of $6,247 in the income tax of the petitioners for the calendar year 1966. Edwin A. Snow was a member of a partnership which reported a net loss for 1966 by reason of a deduction claimed under section 174, I.R.C. 1954, for expenditures for research and experimentation. Respondent disallowed the pro rata share of such loss claimed by the petitioners. The sole issue for decision is whether such expenses are properly...

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