Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for 1971 in the amount of $3,957.72. The sole issue for decision is whether losses sustained by petitioners in 1971 as a result of advances to, or payments on behalf of, a corporation organized by petitioner Bennett I. Miller are deductible as business bad debt losses under section 166(a)
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