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NICKESON v. C.I.R.

No. 90-9007.

962 F.2d 973 (1992)

Daniel B. NICKESON and Enid C. Nickeson; Norman E. Kuhl and Nancy J. Kuhl, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

April 24, 1992.

Attorney(s) appearing for the Case

Declan J. O'Donnell, Englewood, Colo., for petitioners-appellants.

Bridget M. Rowan, Attorney, Tax Div. (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and Gilbert S. Rothenberg, Attorneys, Tax Div., with her on the brief), Dept. of Justice, Washington, D.C., for respondent-appellee.

Before LOGAN and SEYMOUR, Circuit Judges, and WINDER, District Judge.

LOGAN, Circuit Judge.

Daniel B. and Enid C. Nickeson and Norman E. and Nancy J. Kuhl (taxpayers) appeal the decision of the United States Tax Court reported as Brock v. Commissioner, 58 T.C.M. (CCH) 826 (1989), which upheld the disallowance of deductions taken on taxpayers' 1982 returns for research and development expenses, the imposition of penalties under I.R.C. § 6661 for substantial understatement of tax and under...

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