Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined an $837 deficiency in petitioners' 1977 Federal income taxes. The sole issue for decision is whether petitioner, Robert G. Hershenhorn, is entitled to deduct his distributive share of the losses claimed by the respective partnerships, Canyon Associates and Elk Creek Associates.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
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