MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $9,170 for the taxable year 1995. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The sole issue in this case is whether petitioner is required under section 263A, to capitalize...
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