Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined that for 1979 there is a deficiency in petitioners' income tax of $32,098 and an addition to tax under section 6653(a) of $1,605. After concessions, the only issues remaining for decision are: (1) whether a payment of $65,000 made by Michael J. Gevirtz to Belyn Corporation for consulting services is the expense of a limited partnership or of Gevirtz as its general partner and ...
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