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PITTLER v. COMMISSIONER

Docket No. 12457-84.

51 T.C.M. 1587 (1986)

T.C. Memo. 1986-320

Burton R. Pittler and Elin Pittler v. Commissioner.

United States Tax Court.

Filed July 28, 1986.

Attorney(s) appearing for the Case

John P. Kelly, for the petitioners. John O. Kent and Ross Paulson, for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes of $7,630 in 1975 and $726 in 1976. After a concession by petitioners, the sole issue for decision1 is whether the partnership Royal Kuhio XI engaged in bona fide transactions during the years in issue, which would give rise to deductible losses by petitioners...

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