Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined a deficiency in petitioners' federal income tax for the taxable year 1970 in the amount of $67,625.49. This deficiency resulted from respondent's disallowance of three business bad debts and a "compensation for services" expense claimed by petitioners as employee business expenses on their individual tax return for 1970.
Respondent determined that these debts were...
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