Memorandum Findings of Fact and Opinion
POWELL, Special Trial Judge:
Respondent determined a deficiency in petitioners' 1979 Federal income tax in the amount of $73,287. The deficiency is attributable to respondent's disallowance of both partnerships and Schedule C losses claimed by petitioners on their 1979 return. The partnership loss has been severed from the case before us. The sole issue for decision is whether the consent...
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