FEATHERSTON, Judge:
Respondent determined a deficiency of $104,937.46 in petitioners' income tax for 1966. The issues remaining for decision are as follows:
(1) Whether petitioners' pro rata share of the proceeds of a purported loan of $500,000 by the Jupiter Corp. to Empire Properties, a partnership of which petitioner Milton Falkoff was a member, was taxable income;
(2) Whether petitioners' pro rata share of a $274,275 distribution to Empire...
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