Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $2,570,061.99 in petitioners' Federal income taxes for 1971. The deficiency resulted from disallowance of a claimed partnership loss in the amount of $4,202,345 arising out of a limited partnership in which Richard D. Bokum had an interest. The issues for decision are (1) whether the statutory notice of deficiency was valid; (2) whether the burden of proof is on petitioners...
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