BRYAN, Circuit Judge.
The Board of Tax Appeals sustained a deficiency income tax assessment for the years 1927 and 1928 on the theory that the taxpayer should be treated as a member of a partnership and not allowed to take deductions for the full amount of the partnership losses. It is contended in support of this petition for review that the taxpayer was entitled to deduct from his income tax returns the full amount of the business losses, because there was in fact...
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