Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Taxable year Deficiency April 1, 1971-March 31, 1972 ...... $10,207.07 April 1, 1972-March 31, 1973 ...... $ 7,849.46
The sole issue for decision is whether interest on loans from petitioner to a related corporation...
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