Mato L. Marinovich and Daphne Marinovivch - Page 7




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          transactions of the partnerships were tax-motivated and did not             
          constitute legitimate for-profit business transactions.                     
          Petitioners agree to be bound by Krause v. Commissioner, supra,             
          with respect to the activities of White Rim.  Therefore, we                 
          conclude that the activities and transactions of the White Rim              
          partnership, like those of Technology 1980, were not legitimate             
          profit-oriented business dealings and lacked economic substance.            
               Because the activities and transactions of the White Rim               
          partnership lack economic substance, petitioners are not entitled           
          to a loss deduction under section 165(c)(2) for their cash                  
          investment in the White Rim partnership, notwithstanding their              
          individual profit objective in investing in the partnership.                
               To reflect the foregoing,                                              

                                             An appropriate order will be             
                                        issued.                                       




















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