Memorandum Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency of $38,628 in petitioner's Federal income tax for the taxable year 1976.
The issue for decision is what amount, if any, is petitioner, as a limited partner, entitled to deduct as his distributive share of the loss claimed by Whitley Associates, Ltd., a limited partnership. Resolution of this issue is dependent upon whether...
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