Memorandum Opinion
GOFFE, Judge:
The Commissioner determined deficiencies of $21,658.33 and $74,753 in petitioners' Federal income tax for the taxable years 1967 and 1968, respectively. There remain, after concessions by petitioners, two issues for our decision:
(1) Whether the unpaid portion of a loan made by Curtis R. Richmond (hereinafter petitioner) to Ronald Schmidt became a "wholly worthless debt" in 1968, thus allowing its deduction in that...
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