Petitioner, during 1971 and 1972, was a general partnership formed in December, 1969 under the Laws of New York, and consisted of Stephen Swid and Kenneth Pearlman as its sole general partners. This general partnership served as the general partner of two limited partnerships, and engaged in managing the investments of the two limited partnerships, namely Swid Investors and Southwing Investors. Petitioner's income for the years in issue was derived principally from services...
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