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AGRO SCIENCE CO. v. C.I.R.

No. 90-4265.

934 F.2d 573 (1991)

AGRO SCIENCE CO., and Bavaro Investment Co., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. R & D PARTNERS-82, and Donald D. Spear, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. ALPHA MEDICAL RESEARCH ASSOCIATES, and Marc Geller, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 25, 1991.

Attorney(s) appearing for the Case

William D. Wright, William E. Bailey, Bailey, Vaught, Robertson & Co., Dallas, Tex., for petitioners-appellants.

Abraham N.M. Shashy, Jr., Chief Counsel, IRS, Shirley D. Peterson, Asst. Atty. Gen., Dept. of Justice, Tax Div., Kimberly Stanley, Kenneth L. Greene, Gary R. Allen, Chief, Appellate Sec., Tax. Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before REAVLEY, JONES and SMITH, Circuit Judges.

REAVLEY, Circuit Judge:

The Commissioner of Internal Revenue (Commissioner) issued final partnership administrative adjustment notices to appellants Agro Science Company (Agro), R & D Partners — 82 (R & D), and Alpha Medical Research Association (Alpha) (collectively the Partnerships). The Commissioner's notices denied the Partnerships' deductions on their 1982 and 1983 tax returns for expenses incurred in conjunction with research contracts that each...

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