Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for tax years 1981 and 1982 in the amounts of $35,797.00 and $19,101.00, respectively. The issue is whether petitioners are entitled to deduct as business bad debts certain amounts paid by Louis Durante during his lifetime as the guarantor of a corporate loan.
Findings of...
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