Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1978 and 1979 in the amounts of $36,555 and $569, respectively.
The issues for decision are (1) whether William L. Bliss (petitioner) through his sole proprietorship was engaged in a joint venture with his wholly owned corporation of furnishing services to third parties or had entered into equipment leases...
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