Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioner's income tax for the taxable year 1941 in the amount of $7,450.31. The deficiency was based on the disallowance, in part, of certain deductions, of which only one, in the amount of $15,000, is presently in dispute. The first and principal issue here is whether the sum of $15,000 advanced by petitioner over a period of years constituted a loan or a contribution to the capital...
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