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assets so that if trade or business use would be made of any
research or experimental expenditures, then it would be made in
Systems’ trade or business, and not in IRC’s or RIC’s.
Because of our determination, based on our findings of fact
(see Levin v. Commissioner, 832 F.2d 403, 405 (7th Cir. 1987),
affg. 87 T.C. 698 (1986)), that any research or experimental
expenditures by IRC and RIC were not paid in connection with
IRC’s or RIC’s trade or business within the meaning of section
174(a)(1), it is unnecessary for us to determine whether IRC or
RIC made relevant expenditures in 1984 in at least the amounts of
their respective claimed deductions, or in any amounts, and
whether the expenditures that IRC or RIC made qualify as research
or experimental expenditures. Green v. Commissioner, 83 T.C. at
691.
Decisions will be entered
for respondent.
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