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CHUNG v. COMMISSIONER

Docket Nos. 19934-83, 21451-83.

51 T.C.M. 777 (1986)

T.C. Memo. 1986-131

James A. Chung and Carole Chung v. Commissioner. Nello Tiberio and Marilyn Tiberio v. Commissioner.

United States Tax Court.

Filed April 1, 1986.

Attorney(s) appearing for the Case

Michael J. Christianson, for the petitioners. Michael K. Phalin, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined deficiencies in 1978 Federal income tax of petitioners James A. Chung and Carole Chung and petitioners Nello Tiberio and Marilyn Tiberio equal to $27,615 and $34,954, respectively. The issues for decision are (1) whether petitioners may deduct under section 1741 a portion of certain research and experimental expenditures allegedly incurred by a certain...

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