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ADLER v. COMMISSIONER

Docket No. 24848-85.

58 T.C.M. 594 (1989)

T.C. Memo. 1989-597

Alfred K. Adler v. Commissioner.

United States Tax Court.

Filed October 31, 1989.

Attorney(s) appearing for the Case

Richard C. Fox, Miami, Fla., for the petitioner. William B. McCarthy, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined deficiencies in petitioner's Federal income taxes for 1981 and 1982 in the amounts of $17,407 and $10,081, respectively, and an addition to tax pursuant to section 66611 for 1982 in the amount of $1,006.

The issues for decision are: (1) whether petitioner is entitled, in 1981 and 1982, to a distributive share of losses and credits claimed as...

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