Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioners' 1977 and 1978 Federal income tax returns in the amounts of $74,569.34 and $73,783.94, respectively. The issues for decision are whether petitioner is precluded from denying that capital is a material income-producing factor in Mr. Berry's parking facilities business for the years in issue under the principle of collateral estoppel; and if collateral...
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