MEMORANDUM OPINION
FAY, Judge:
Respondent determined deficiencies of $6,611 and $5,753 in petitioner's 1990 and 1991 Federal income tax, respectively. The issues for decision are: (1) Whether petitioner is entitled to deduct passive activity losses claimed in 1990 and 1991, and (2) whether petitioner is entitled to a foreign tax credit of $55 for taxable year 1990.
When called for trial, the parties did not call any witnesses or present any evidence...
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