Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax against petitioners in the amounts of $12,163.30 for 1962 and $119.10 for 1963.
The only issue for decision is whether the taxpayers are entitled to deductions for the taxable years 1962 and 1963 in the respective amounts of $57,621.51 and $38,500 which amounts were paid by Abraham Gosman in full satisfaction of his liability as guarantor...
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