Memorandum Findings of Fact and Opinion
COHEN, Judge:
In these consolidated cases, respondent determined deficiencies in Federal income tax for the calendar year 1978 of $164,729.96 for Michael G. Jolin and Susan P. Jolin and $159,615.52 for Charles F. Witte and Patricia G. Witte.
After concessions, the issues for decision are: (1) whether Builder's Service Group of Ohio, Inc. was general partner of certain limited partnerships, and if so, whether...
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