Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined a deficiency in income tax due from the petitioners for the taxable year 1972 in the amount of $13,891.00. The sole question for decision is whether a partnership known as STD I, LTD. sustained a loss for the calendar year 1972 and, if so, whether the amount thereof is deductible by petitioners in their individual income tax return for that year.
Findings of Fact
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