ESCHBACH, Circuit Judge.
Alan F. Segal and his wife ("Segal") claimed deductions on their joint income tax returns during the years 1979 through 1982 flowing from Alan Segal's share in a general partnership which purchased rights in a motion picture. The Commissioner of Internal Revenue ("Commissioner") disallowed these deductions and issued a notice of deficiency. Segal petitioned the United States Tax Court for relief pursuant to 26 U.S.C. §§ 6213 and...
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