Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1970 in the amount of $2,926.42. The issues for decision are:
(1) Whether petitioner is entitled to a deduction for intangible drilling and development costs in connection with a limited partnership agreement which he entered into with Moray Oil Producers 1970, Inc. of Los Angeles, California; and
(2) In...
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