Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in the amounts of $9,193.49 and $1,648.17 in petitioners' Federal income taxes for 1976 and 1977, respectively. The sole issue for decision is whether capital was a material factor in producing partnership income from a real estate business so that only 30 percent of petitioners' distributive share of that income is eligible for the maximum tax limitations prescribed...
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