MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
For taxable years 1995 and 1996, respondent determined deficiencies of $47,775 and $53,144, respectively, in petitioners' Federal income taxes. The sole issue for decision is whether petitioners are entitled to deduct as real property taxes, or as business expenses, amounts paid by petitioner husband (petitioner) with respect to properties owned by two partnerships in which petitioners' wholly owned...
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