Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency in the income tax of petitioners for the taxable year 1958 in the amount of $62,551.77. The only issue presented is whether petitioners are entitled to a business bad debt deduction in the amount of $117,184.47 for the taxable year 1958, or in the alternative, to a nonbusiness bad debt deduction for that year.
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