CLAPP, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $8,186 and $56,344 for the tax years 1984 and 1985, respectively.
After concessions by the parties, the sole issue for decision is whether petitioners are entitled to deduct their distributive share of partnership loss on their 1985 Federal income tax return.
All section references are to the Internal Revenue Code for the years in issue and...
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