Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $737.00 in petitioners' Federal income tax for 1977. The only issue is whether petitioners realized taxable income as a consequence of interest-free loans made to petitioner-husband by a corporation he controlled.
All the facts have been stipulated and are found accordingly.
Petitioners, Lee O. Ruwe...
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