Memorandum Findings of Fact and Opinion
HALPERN, Judge:
Respondent determined deficiencies in petitioners' 1983 and 1984 Federal income tax in the amounts of $20,098.50 and $39,106.57, respectively. The deficiencies result from respondent's disallowing capital gains deductions for payments received by petitioner Milton Tolmach on account of the dissolution of a law firm of which he was a partner. We must...
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