Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
The respondent determined a deficiency in the petitioners' Federal income tax for 1953 in the amount of $3,647.47. The deficiency arises from respondent's disallowance of a deduction of $9,500 as a business bad debt for 1958. The amount in question represents the unpaid balance of loans made by the petitioner, Frank A. Garlove, (hereinafter referred to as the petitioner or Garlove) to a corporation...
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