MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $8,691 and $5,024 for 1993 and 1994, respectively, and a penalty under section 6662(a) of $1,738 for 1993.
After concessions by the parties, the issue remaining for decision is whether petitioners may disregard their S corporation and have its losses treated as partnership losses.
Unless otherwise indicated, all section...
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