Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $92,495.10 in the petitioner's Federal income tax for 1974. After a concession by the petitioners, the sole issue for decision is whether the petitioners, as limited partners in an oil and gas drilling partnership, are entitled to deduct intangible drilling and development costs in 1974, the year in which the partnership entered into turnkey contracts for...
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