Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency of $9,429.21 in petitioner's Federal income tax for his 1981 taxable year. The deficiency was based primarily on adjustments resulting from the disallowance of petitioner's distributive share of losses from Fluid Technology, Inc. ("Fluid Technology"), a subchapter S corporation. The issues we must decide are (1) whether Fluid Technology was carrying on any trade...
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