Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the year 1946 in the amount of $3,039.46. The sole question is whether loans made by petitioner to a corporation in which he was active and owned one-half the stock created a "non-business" debt within the meaning of Section 23 (k) (4) of the Internal Revenue Code.
Findings of Fact
The petitioner is an individual and filed his income...
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