Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined a deficiency of $2,430.70 in petitioners' Federal income tax for calendar year 1974.
As we understand it, the deficiency results from respondent's determination that the worthlessness of a $10,000 loan made by petitioner, John N. Bowers, to a Mr. Basiliko should be treated as a nonbusiness bad debt loss under section 166(d), I.R.C. 1954, as amended,
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