Memorandum Findings Of Fact and Opinion
GERBER, Judge.
Respondent, by notice of deficiency, disallowed petitioners, claimed deduction for worthless loans made to their daughter and determined a deficiency of $9,800 in petitioners' 1987 Federal income tax. Respondent, in the notice of deficiency, determined that advances made by petitioners to their daughter were gifts rather than loans. If we decide that the advances were loans, respondent alternatively...
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