Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Tax Year Ended Deficiency 1972 ............. $ 9,515 1973 ............. 11,262 1974 ............. 3,670 1975 ............. 370
The sole issue for decision is whether a bad debt arising in 1975 out of a loan to petitioners' closely held corporation...
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