Memorandum Opinion
DAWSON, Judge:
This matter is before us on respondent's motion for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure. Petitioners have filed a memorandum opposing the motion.
Respondent determined a deficiency of $34,483 in petitioners' Federal income tax for the year 1977. Included in the four adjustments to income made in the notice of deficiency is a claimed Schedule C loss of $36,800 which...
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