MEMORANDUM OPINION
COUVILLION, Special Trial Judge:
This case was heard pursuant to section 7443A(b)(3)
Respondent determined a deficiency of $2,925 in petitioners' Federal income tax for 1991. The issues for decision are: (1) Whether petitioners are entitled, under section 174(a), to a deduction for the cost of an automobile engine that was used in connection with a research or experimentation...
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