Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined a deficiency of $25,403.56 in petitioners' income tax for 1976. The only issue is whether petitioners are entitled to deduct a loss in the amount of $55,639 as a result of the interest of petitioner David A. Weinstein in a partnership known as Cay Associates.
Findings of Fact
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