Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ended June 30, 1984, in the amount of $469,749. The issues for decision are: (1) whether petitioner properly deducted $1,070,000 as a "distribution of funds among partnership," and, if not, (2) whether petitioner is nonetheless entitled to a deduction of all or part of that amount as an ordinary and necessary...
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