Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1979 of $6,388.00. The sole issue for decision is petitioners' distributive share of Global Partners, Ltd.'s partnership loss.
All of the facts have been stipulated. The stipulations of fact and attached exhibits are incorporated herein by this reference.
Petitioners are husband and...
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