MEMORANDUM OPINION
NAMEROFF, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3)
Respondent determined a deficiency in petitioners' Federal income tax for 1990 in the amount of $5,090. The sole issue to be decided is whether petitioner is entitled to any deduction in connection with an alleged business bad debt of $32,722, which respondent disallowed...
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