Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in Federal income tax of petitioners Elton and Norma Louise Brimberry for the calendar years 1966, 1967 and 1968 in the amounts of $20,875.71, $49,213.25 and $32,500.13, respectively. Due to concessions by the parties, the only issue for our decision is whether petitioners are entitled to deductions for a partially worthless business bad debt under section 166(a) (2...
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