SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioners' Federal income taxes of $7,962 for 1978 and $17,146 for 1979. The issues for decision are: (1) Whether William J. Law, as a limited partner in a partnership purportedly engaged in the purchase and distribution of a motion picture, is entitled to deductions for a distributive share of losses reported by the partnership and, if so,
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