Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $3,144.00 in the petitioners' Federal income tax for 1972. The issues for decision are: (1) Whether the members of a partnership are entitled to deduct intangible drilling costs in 1972, the year in which the partnership entered into a contract for the drilling of oil and gas wells; and (2) whether in that year, the partnership incurred any deductible management...
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