Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies in the petitioners' income tax for the years 1954 and 1955 in the respective amounts of $2,706.64 and $2,147.17. The issues are:
1. Whether loans in the amount of $44,027.80 made by petitioners to the Ellis Curtain Company and which became worthless in 1954 are deductible in that year as a business bad debt or as a nonbusiness bad debt; and
2....
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