PER CURIAM.
Petitioners-Appellants Frederick and Linda Todd appeal the decision of the United States Tax Court that a purported $400,000 loan to Frederick was taxable income (and not a loan) and therefore found the Todds liable for both income tax deficiency and a penalty under I.R.C. § 6662(a). Because the Tax Court did not clearly error in finding that the purported $400,000 loan was income nor in finding that the Todds had failed...
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