Memorandum Findings of Fact and Opinion
IRWIN, Judge:
The Commissioner determined a deficiency in petitioners' income tax for the calendar year 1962 in the amount of $26,040.18.
Since petitioners conceded certain issues at trial and on brief, the sole issue remaining for consideration is whether certain loans by the late A. M. Saperstein to the now-defunct American Basketball League, which became...
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