Memorandum Findings of Fact and Opinion
FAY, Judge:
The Commissioner determined a deficiency in petitioners' income tax for the year 1959 in the amount of $4,266.54. The only issue for decision is whether the sum of $15,749.59 paid by petitioner as guarantor is deductible as a business bad debt or nonbusiness bad debt.
Findings of Fact
Some of the facts have been stipulated and are so found.
Petitioners Sol Gelfond (hereinafter...
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