Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined deficiencies in petitioners' 1985 and 1986 Federal income taxes of $48,487.65 and $17,317.67, respectively. Petitioners, on their 1985 Federal income tax return, claimed a $295,618 deduction from ordinary income attributable to a business bad debt. This claimed deduction resulted in a net operating loss, which petitioners elected to forgo as a carryback and claimed as a net operating...
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