Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the taxable years 1972 and 1974 in the amounts of $26,009 and $48,788.05, respectively. After concessions, the issues for decision are:
(1) Whether petitioner David Koss entered into a "joint venture" with Lester Wolser relating to the liquidation of their interests in the Dynetics Corporation or entered into an agreement...
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