OPINION
RAUM, Judge:
This case involves the Commissioner's determination that certain expenses deducted in Von-Lusk's returns for 1988, 1989, and 1990, were not deductible but instead were to be capitalized under section 263A.
Von-Lusk (also referred to as the partnership) is a California limited partnership. Petitioner, the Lusk Co., is an S corporation and was the tax matters partner of Von-Lusk for 1988, 1989...
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