Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies of $15,563 for 1979 and $52,642 for 1981 and an addition to tax of $13,160 for 1981 under section 6651(a)(1). David Krebs was a successful contemporary musical and theatrical promoter in the years at issue. Respondent disallowed: (1) Deductions attributable to expenses to promote Cheryl Krebs' music career, and (2) losses attributable to certain theatrical production...
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