Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioner's 1984 Federal income tax in the amount of $55,879, and an addition to tax for that year under section 6661(a)
The issues presented for decision are: (1) whether petitioner's distributive share of a limited partnership's income is exempt from taxation by virtue of the 1942 Income Tax Convention...
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