Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners' Federal income tax for the years 1972 and 1973, in the respective amounts of $7,920.98 (corrected by the parties' Stipulation of Facts to $7,842.83 because of a mathematical error), and $9,321.57. The sole remaining issue for our decision is whether petitioners realized taxable income in 1972 and 1973 because of interest-free loans from his closely...
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