Memorandum Findings of Fact and Opinion
WELLS, Judge:
The instant case is a proceeding under section 6226 for a readjustment of partnership items of Pacific Securities (the partnership) for the taxable year ending December 31, 1983. Respondent issued a Notice of Final Partnership Administrative Adjustments in which he (1) disallowed an ordinary loss of $1,037,520 arising from the write-down under section 1.471-5, Income Tax Regs., of securities held by the...
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