MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $31,029.52 in petitioners' Federal income taxes for 1981 and an addition to tax of $6,057.30 under section 6659. The issue for decision is whether petitioner Mark D. Lebow (petitioner) is entitled to deduct in 1981 the sum of $10,000 invested in Peat Oil & Gas Associates (POGA) during that year. Unless otherwise indicated, all section references are to the Internal...
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