Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency in petitioners' 1981 income tax in the amount of $10,499.52. The deficiency arises as a result of an unprofitable investment made by William T. Schnurr (petitioner) in an attempt to acquire interests in both the Canaan Oil Company, Inc. and Canaan Oil and Fuel Company (together referred to as Canaan or the Company) for which a business bad debt deduction was claimed...
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