Memorandum Opinion
RAUM, Judge:
The Commissioner determined an $807 deficiency in petitioners' 1974 income tax. The only question presented is whether Cal Pac Recreational Development Company, Inc., a corporation whose sole shareholder is a partnership in which petitioners have a 10 percent interest, qualifies as an electing small business corporation, thereby entitling petitioners to deduct their proportionate share of the corporation's losses as part of...
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