United States Tax Court.
Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent disallowed all of Active Lipid Development Partners, Ltd.'s (Active Lipid or the partnership) expenses for tax year 1983, as follows:
Research and Development Expense .................................... $540,000
Amortized Organization Costs ........................................ 200
Amortized Start-Up Costs ............................................ 17
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