Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $22,662 in petitioner's 1979 Federal income tax. After concessions by petitioner, the issue for decision is whether petitioner must recognize ordinary income during 1979 on the exchange of $35,000 in managerial services for a partnership capital interest, and if so, to what extent.
Findings of Fact
Some of the facts have been stipulated, and the...
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