Memorandum Opinion
LARO, Judge.
This case was submitted to the Court fully stipulated. Shirley McVay Wiseman petitioned the Court to redetermine respondent's determination of a $69,759 deficiency in her 1989 Federal income tax and a $13,952 penalty under section 6662. Following concessions by the parties, the sole issue for decision is whether section 469 prevents petitioner from aggregating her distributive...
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