Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
In these consolidated cases the Commissioner determined adjustments to the 1982 and 1983 Federal partnership returns for the Agro Science Company ("Agro"), R&D Partners - 82 ("RDP"), and Alfa Medical Research Associates ("Alfa") by denying deductions as follows:
Agro 1982 R&D expense .................... $593,353.29 Accounting fees .......
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