United States Tax Court.
Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1979 in the amount of $20,731. The sole issue for determination is whether petitioner realized $63,467 of ordinary income during the taxable year in issue as a result of his withdrawal as a partner from an accounting partnership.
Findings of Fact
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