Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioners' 1981 Federal income tax in the amount of $13,385.48.
The issues this Court must decide are (1) whether the statute of limitations bars assessment of any tax due in respect of petitioners' 1981 Federal income tax return, (2) whether petitioners are entitled to a deduction for research and experimental expenditures...
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