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ALLEN v. COMMISSIONER

Docket No. 363-85.

55 T.C.M. 641 (1988)

T.C. Memo. 1988-166

Edward H. and Susan W. Allen v. Commissioner.

United States Tax Court.

Filed April 21, 1988.

Attorney(s) appearing for the Case

Stephen J. Plowman, 196 S. 100 W., Logan, Utah, for the petitioners. Joel A. Lopata, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, by a statutory notice of deficiency dated October 4, 1984, determined deficiencies in petitioners' Federal income tax for the years 1980, 1981 and 1982, in the amounts of $4,204, $14,810.59, and $1,689, respectively.1 After concessions, the issues remaining for our consideration are whether petitioners: (1) are entitled to claim losses generated by the partnership...

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