Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
By statutory notice dated June 24, 1988, respondent determined a deficiency in petitioners' 1983 Federal income tax in the amount of $26,025 and an addition to tax for a substantial understatement of income tax in the amount of $6,506.25. The issues for decision are: (1) whether a payment made in 1983 pursuant to a personal guarantee of corporate obligations gave rise to a business bad debt, deductible...
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