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UNITED FIBERTECH, LTD. v. C.I.R.S.

No. 92-1265.

976 F.2d 445 (1992)

UNITED FIBERTECH, LTD.; Kevin T. Twohy, Tax Matters Partner, Appellants, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided September 24, 1992.

Attorney(s) appearing for the Case

Robert B. Martin, Jr., Pasadena, Cal., argued, for appellants.

Mary Francis Clark, Washington, D.C., argued (Gary R. Allen, James A. Bruton and Richard Farber, on the brief), for appellee.

Before FAGG, Circuit Judge, HENLEY, Senior Circuit Judge, and MAGILL, Circuit Judge.

PER CURIAM.

United Fibertech, Ltd. appeals the tax court's order denying it a tax deduction under 26 U.S.C. § 174(a)(1) (1988). We affirm.

The facts are fully developed in the tax court's opinion reported at United Fibertech, Ltd. v. Commissioner, 62 T.C.M. (CCH) 699 (1991), and we do not repeat them here. Fibertech contends it is entitled to a tax deduction under section 174(a)(1) for research and experimental...

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