Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined a deficiency of $19,179.25 in petitioners' 1988 Federal income tax. The deficiency was attributable to respondent's disallowance of a $58,119 subchapter S pass-through loss reported on petitioners' 1987 income tax return and carried over to their 1988 income tax return as part of a net operating loss. By amendment to answer, respondent alleged an increase in deficiency attributable...
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