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In sum, we hold that the research and developmental
expenses incurred by Research II during December 1982 were not
made in connection with its trade or business within the meaning
of section 174(a). We have considered the parties' remaining
arguments and find them without merit, irrelevant, or
unnecessary to reach.
To reflect the foregoing and the concessions of the
parties,
Decision will be entered
under Rule 155.
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