Memorandum Findings of Fact and Opinion
KORNER, Judge.
By statutory notice of deficiency dated January 11, 1990, respondent determined deficiencies in petitioner's 1985, 1986, and 1987 Federal income tax in the amounts of $4,408, $5,796, and $3,682, respectively. The issue for decision is whether respondent erred in determining that petitioner was not entitled to deduct the pass-through of losses from an S Corporation for all 3 years at issue, nor to an...
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