Memorandum Findings of Fact and Opinion
FISHER, Judge:
This proceeding involves deficiencies in income taxes determined against petitioners as follows:
Year Amount 1952 ......... $ 609.19 1953 ......... 931.14 _________ Total ........ $1,540.33
The principal issue presented for our decision is whether the worthlessness of the balance of the advances made by petitioner to a...
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