Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1973 and 1974 in the amounts of $1,410 and $3,046, respectively.
The issue for decision is whether petitioners are entitled to a business bad debt deduction in 1973 or 1974 because of the worthlessness of loans made by petitioner Bernard J. Liebmann to his wholly owned corporation, Liebmann Transportation Co....
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