MEMORANDUM OPINION
WELLS, Chief Judge:
Respondent determined deficiencies in petitioner's 1994 and 1995 Federal income taxes in the amounts of $5,750 and $18,541 respectively.
The issues for decision are: (1) Whether petitioner is entitled to a $120,800 business bad debt deduction for 1994 (with a resultant net operating loss carryforward to 1995 of $71,143) for loans made to her son's business; and, (2) whether a substantial portion (67 percent...
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