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BOYNTON v. COMMISSIONER

Docket No. 10526-77.

72 T.C. 1147 (1979)

JOE T. BOYNTON AND HELEN J. BOYNTON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 24, 1979.

Attorney(s) appearing for the Case

Robert O. Rogers, for the petitioners.

Hans G. Tanzler III, for the respondent.

RAUM, Judge:

The Commissioner determined deficiencies in petitioners' Federal income taxes as follows:

Year                  Deficiency

1971 ...............     $32,917
1972 ...............       1,567
1973 ...............        $505
1974 ...............     168,498

After concessions, the sole issue for decision is whether petitioner is entitled to deduct as his distributive share of partnership losses all of the...

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