Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1961 and 1962 in the amounts of $22.86 and $1,435.89, respectively.
The only issue for determination is whether the amount of $12,186.53 paid by petitioner Philip W. Fitzpatrick in 1962 as a coguarantor on a corporate obligation was deductible as a business or as a nonbusiness bad debt.
The other adjustments...
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