MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $2,422 deficiency in petitioners' 1995 Federal income tax.
The issue for decision concerns petitioners' entitlement to a deduction on their individual 1995 Federal tax return for claimed losses incurred by Legal Search, Inc., all the stock of which is owned by Lloyd L. Barber (petitioner). Resolution of this issue depends upon whether a timely election on Form 2553 was...
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