Patrick F. and Arlene Gwon Sheehy - Page 1

                                    T.C. Memo. 1996-334                                      

                                 UNITED STATES TAX COURT                                     

                   PATRICK F. AND ARLENE GWON SHEEHY, Petitioners v.                         
                      COMMISSIONER OF INTERNAL REVENUE, Respondent                           

                Docket No. 17799-94.              Filed July 24, 1996.                       

                Ralph C. Larsen, for petitioners.                                            
                Christine V. Olsen, for respondent.                                          

                         MEMORANDUM FINDINGS OF FACT AND OPINION                             

                JACOBS, Judge:  Respondent determined a $57,301 deficiency in                
          petitioners' 1991 Federal income tax, and an $11,460 section                       
          6662(a) accuracy-related penalty for that year.                                    
                The issues for decision are (1) whether petitioners are                      
          entitled to deduct as research and development expenses $165,000                   

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