Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in income tax against the petitioners of $1,411.16 for 1947 and $2,121.56 for 1948. The questions presented are whether valid debts were created as a result of loans made by the petitioner, and, if so, whether the losses from the worthlessness of these debts were incurred in
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