Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined a deficiency in the petitioners' income taxes for the taxable calendar year 1957 in the amount of $1,031.54. The sole question for decision is whether the petitioners are entitled under section 166(a) of the 1954 Code to a business bad debt deduction of $24,444.27 for the year 1957, arising out of unrepaid advances to, and payments of obligations for, a corporation of which...
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