Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency of $26,474 in petitioner's 1976 Federal income tax. The deficiency resulted from the disallowance of a loss of $72,396 which petitioner claimed as his distributive share of the losses of The Cumberland Group, a limited partnership formed in 1976 purportedly to lease and mine certain coal property in West Virginia. The following issues are presented for decision:
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