In this proceeding, the petitioner contends that the determination of the respondents, assessing a deficiency of $4,917.72, lacks a substantial evidentiary basis. In his lifetime the decedent, a resident of New Jersey, acquired a 3.4977% interest, by a capital contribution of $50,000, in Endeavor Car Company (Endeavor), a partnership established under the laws of New York. This partnership consisted of two general partners and 18 limited ones, one of whom was the decedent...
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