NIMS, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Year Deficiency 1979 .................. $40,701.00 1980 .................. 54,942.12 1981 .................. 35,482.90
The issues for decision are:
(1) Whether the transactions between the partnerships, executive producers, and producers were tax shams lacking economic substance;
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