Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1960 in the amount of $2,127.30.
The issue for decision is whether petitioners are entitled to a deduction as an ordinary loss or as a business bad debt of amounts which one of petitioners had partially paid and partially given notes to pay on behalf of a corporation, the stock of which was owned by petitioners...
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