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HASLAM v. COMMISSIONER

Docket No. 5463-70.

33 T.C.M. 482 (1974)

T.C. Memo. 1974-97

Charles J. and Harriet S. Haslam v. Commissioner.

United States Tax Court.

Filed April 18, 1974.

Attorney(s) appearing for the Case

Anthony J. Feeney, Jr., 91 Front Grove Road, Slingerlands, N.Y., for the petitioners. H. Stephen Kesselman, for the respondent.

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1967 in the amount of $979.01 and a penalty pursuant to section 6651(a)1 in the amount of $244.75.

The only issue for our decision is whether petitioners are entitled to business or nonbusiness deductions for losses arising from their guarantee of debts of Charles J. Haslam...

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