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DOUBLE BAR CHAIN CO., LTD. v. COMMISSIONER

Docket No. 39308-87.

62 T.C.M. 1276 (1991)

T.C. Memo. 1991-572

Double Bar Chain Co., Ltd., Selway Technology Inc., Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed November 25, 1991.

Attorney(s) appearing for the Case

James A. Ririe, 515 S. Third St., Las Vegas, Nev., for the petitioner.

Paul K. Voelker, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

Respondent, pursuant to section 6223,1 mailed a notice of final partnership administrative adjustment (FPAA) in regard to Double Bar Chain Co., Ltd. (Double Bar), for 1983. The primary issue for decision is whether $479,500 in research and experimental expenditures were incurred by Double Bar in connection with a trade or business.

Findings of Fact

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