Memorandum Findings of Fact and Opinion
PARR, Judge.
Respondent determined an adjustment to the partnership return of income of United Fibertech, Ltd. (hereinafter sometimes referred to as the partnership) for the tax year ended December 31, 1983, due to disallowance of a deduction for Research and Experimental Expense in the amount of $2,280,000.
The issues for decision are: (1) Whether purported research and experimental expenditures paid by the...
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