Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined a deficiency in petitioners' income tax for 1960 in the amount of $14,586.75. The issues are (1) whether petitioners are entitled to a deduction in 1960 because of the purported worthlessness in that year of certain loans (or, in the alternative, capital advances) made by petitioners to their wholly-owned corporation; and (2) whether petitioners are entitled to a deduction as...
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