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DIPIERO v. COMMISSIONER

Docket No. 21967-85.

57 T.C.M. 71 (1989)

T.C. Memo. 1989-161

Domenic M. DiPiero and Rosera S. DiPiero v. Commissioner.

United States Tax Court.

Filed April 13, 1989.

Attorney(s) appearing for the Case

David A. Schmudde, 535 5th Ave., New York, N.Y., and Martin M. Shenkman, 1375 Broadway, New York, N.Y., for the petitioners. Frank Agostino, C. Ellen Pilsecker, Matthew Magnone and Patrick E. Whelan, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1981 in the amount of $81,683.48, which stems from petitioners' investment in a movie partnership. The issues for decision are: (1) whether the partnership purchased the motion picture, "Conan the Barbarian"; (2) whether the partnership can include the nonrecourse purchase note in basis; (3) whether petitioners' investment is subject...

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