  Kanter contends the Court’s holding in

Estate of Cook is in error.   A more detailed and comprehensive

findings of fact can be found in the reported opinion of Estate

of Cook.

     During 1979, Kanter and three other individuals (including

George Cook, whose estate was the taxpayer in Estate of Cook,

invested in IRC.   None of the stockholders in IRC, including

Kanter, had any formal educational background or experience in

the field of pharmaceutical compounds, which was the business IRC

was set to engage in.

     Shortly after IRC was organized, IRC entered into a

research/licensing agreement with Newport Pharmaceutical

International, Inc. (Newport).    Newport was then engaged in the

manufacture, marketing, research, and development of

pharmaceutical compounds.   Newport owned an undivided one-half
 Entitled to a Business
            Deduction of $104,231 for 1980 (STJ report at 173-177)

      Respondent disallowed a deduction of $104,231 that

petitioners claimed on Schedule C of their 1980 tax return.    The

deduction related to a joint venture between two of Kanter’s

clients, Feigan and Rappaport, to purchase a painting of George

Washington.   Kanter was instrumental in bringing the two

businessmen together at the start of the venture.   The

transaction subsequently soured, the painting was returned to its

original owner, and, although the seller returned the full

purchase price, Rappaport, who provided the funds for the

purchase, lost money on account of an intervening decline in the

value of the British pound against the U.S. dollar.