Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes of $70,821.09 for 1981, $25,728.75 for 1982, and $13,002 for 1983 in the notice of deficiency. Respondent later amended the answer to assert an increased deficiency of $162,245.26 for 1981.
Petitioners borrowed money to purchase and develop land in the Virgin Islands. Petitioners were unable to sell the project and transferred...
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