Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies in the income tax of petitioners have been determined by the Commissioner for the taxable years and in the amounts shown below:
Year Deficiency 1964 $375.98 1965 388.91
The issues to be decided are: (1) Whether certain advances made by petitioner to his controlled corporation are bona fide loans or contributions to capital; (2) If...
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