MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined deficiencies in petitioners' income taxes of $52,837 and $73,542 for the taxable years 1989 and 1990, respectively. The sole issue remaining for our consideration is whether petitioners, as S corporation shareholders, may increase their bases in the S corporation by the amount of debt for which they and the corporation were the...
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