Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency in petitioners' 1972 Federal income tax in the amount of $13,659.01. The deficiency is attributable to certain adjustments to petitioner Philip Martin's distributive share of the losses of two real estate partnerships in which he was a partner during 1972. Two issues are presented for decision:
(1) Whether the entire amount of a $64,500 payment to partner Jack...
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