CHASE, Circuit Judge.
These two petitions to review deficiency determinations of income taxes are based on the same facts and were heard together.
The petitioners are brothers who in 1930 were in business, as they had been for some time, in the City of New York as importers and exporters of raw furs. In the year stated each of them loaned to Max M. Frank of Berlin, Germany, an old friend and customer of theirs for many years, the sum of $7,000. Frank was then...
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