Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies of $367,070 and $358,334 in petitioners' Federal income tax for 1969 and 1970, respectively. After concessions, the remaining issue is the amount of deductions allowable with respect to petitioner Ronald R. Levy's participation in an oil drilling venture. The amounts deductible depend on a resolution of the following issues:
(1) whether petitioners, cash basis...
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