Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency of $2,685.84 in petitioners' 1973 income tax. This deficiency was the result of the Commissioner's determination that a $16,735 business bad debt deduction claimed by petitioners in respect of purported loans and loan guarantees for the benefit of LaStaiti Associates, Inc., and other corporations organized by the petitioner-husband, was allowable only as a non-business...
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