Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies of $4,559 and $6,831 in the joint Federal income tax returns of the petitioners for the taxable years 1969 and 1970, respectively. The primary issue for our decision is whether the "limited partnerships" involved in this proceeding constitute associations, taxable as corporations within the meaning of section 7701(a)(3).
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