Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year 1973 in the amount of $1,985. The sole issue to be decided is the correct amount of Petitioner Robert De Michael's distributive share of a partnership loss.
Findings of Fact
Petitioner Robert De Michael (herein petitioner) resided in Canyon County California,
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