Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency in petitioners' Federal income tax of $18,026.90 for the taxable year 1977. After a concession by the parties, the issues for decision are 1) whether loans made by petitioner to a corporation in which petitioner was a one-third shareholder were business debts or nonbusiness debts under section 166(d)
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