Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiences of $3,685.72 and $2,117.76, respectively, in petitioners' 1973 and 1974 Federal income taxes. Because of concessions, the only issue in each year is whether certain corporate distributions made on behalf of petitioner Robert W. Smith were loans or informal dividends.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
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