SIMPSON, Judge:
The Commissioner determined a deficiency of $2,757.23 in the petitioners' Federal income tax for 1972. Both parties have conceded certain adjustments. The issues remaining for decision are: (1) Whether, for Federal tax purposes, partners can agree to allocate retroactively partnership losses to a partner who was not a member of the partnership at the time such losses accrued; and (2) to what extent was a partnership loss incurred after the admission...
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