Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner determined a deficiency in income tax of the petitioners for the year 1949 in the sum of $12,160.38. The sole question for our determination is whether the Commissioner correctly determined that the sum of $30,000 which petitioner William B. Cudlip paid as a guarantor of certain corporate indebtedness is not deductible as a business had debt but should properly be treated as a non-business...
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