MEMORANDUM OPINION
SWIFT, Judge:
Respondent determined deficiencies of $249,919, $96,478, $5,627, and $16,300, respectively, in petitioner's Federal income taxes for 1988, 1989, 1990, and 1991.
The issue for decision is whether petitioner is entitled to a claimed $1.6 million nonbusiness bad debt deduction relating to funds transferred to a closely held corporation.
Background
Petitioner resided in St. Cloud, Minnesota, at...
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