Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined a deficiency of $14,444.56 in petitioners' 1981 Federal income tax.
The sole issue for decision is whether petitioners properly deducted $34,437.75 from their 1981 gross income, Norman W. Ley's (petitioner) ratable portion of a pass through net operating loss sustained by L&T Exploration Inc. (L&T Exploration), a small business corporation (S corporation) in which...
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