Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1982 in the amount of $25,961.05. Concessions having been made, the sole issue remaining for decision is whether certain losses resulting from the transfer of monies and the guarantee of loans are business or nonbusiness bad debts and losses within section 166.
Findings of...
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