Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1969 and 1973 in the amounts of $6,256 and $1,467, respectively.
The issues for decision are:
(1) Whether petitioners are entitled to a business bad debt deduction under section 166(f), I.R.C. 1954,
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