Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner determined a deficiency of $6,336 in petitioners' income tax for the taxable year 1966.
The issues presented for decision are: (1) whether the deduction of $30,000 labeled on petitioners' 1966 income tax return as "investment in venture — business failed" was either "incurred in a trade or business" or a "transaction entered into for profit;" (2) whether petitioners have...
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