Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for 1980 and 1981 in the amounts of $30,126 and $55,339, respectively. The issues for decision are: (1) whether the partnership purchased the motion picture "Flash Gordon"; (2) whether the partnership can include the nonrecourse purchase note in basis; (3) whether petitioners, investment is subject to the limitations of section 465...
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