Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in petitioner's income tax of $8,345 for 1987 and $6,335 for 1988. Respondent also determined that petitioner is liable for an addition to tax of $2,123 under section 6651(a)(1) for 1987 for failure to timely file a return.
The issues for decision are:
1. Whether petitioner may deduct as a business bad debt $22,807.17 that he paid to respondent for the...
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