Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in income tax of the petitioners for the year 1946 in the amount of $20,057.44. The contested issue is whether in the taxable year involved petitioners incurred a loss as a result of loans to Pappy's, Inc., a Florida corporation, and whether, if a loss was incurred, it was a business or a nonbusiness bad debt.
Findings of Fact
Petitioners, husband and wife, are residents...
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