DRENNEN, Judge:
Respondent determined a deficiency and an addition to tax respectively of $4,286.77 and $383.76 with respect to petitioners' income tax for the year 1961.
The issues for decision are: (1) Whether loans made to a partnership became worthless in the year 1961, thereby entitling petitioners to a bad debt deduction; (2) whether certain legal and accounting fees incurred by a subchapter S corporation in connection with proceedings before...
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