OPINION
JACOBS, Judge:
Respondent determined a deficiency of $11,502.58 in petitioners' 1984 Federal income taxes. On their 1984 individual income tax return, petitioners reported a loss of $18,172 as the distributive share of the loss of William E. Aufleger (referred to in the singular as petitioner) from Jokers, King of Comedy, Inc. (Jokers), an S corporation. Respondent determined that Jokers had a gain, not a loss, and that petitioner's distributive...
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