Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice of deficiency dated October 17, 1988, respondent determined deficiencies in petitioners' income taxes for 1982 and 1983 in the amounts of $62,727 and $17,158, respectively. Among the adjustments giving rise to respondent's determination of deficiencies were her disallowance of: (1) A deduction claimed for 1982 with regard to research and experimental expenditures and (2) credits claimed for...
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