Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1980 and 1981 in the amounts of $31,232.25 and $43,091, respectively. The issues for decision are: 1) whether the motion picture partnership "Hearts Associates" transaction lacked economic substance; 2) whether the partnership purchased the motion picture "Second Hand Hearts;" 3) whether the partnership can include...
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