Memorandum Findings of Fact and Opinion.
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1960 and 1963 in the respective amounts of $13,165.64 and $4,057.11. Certain issues having been conceded, the issues remaining for decision are whether petitioners' stock in their wholly-owned corporation, as well as purported loans made by petitioners to such corporation, became worthless in 1963 entitling them to deductions...
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