SIMPSON, Judge:
The respondent determined a deficiency of $9,864 in the income tax of the petitioners for the taxable year 1964. Upon liquidation of a corporation in which he held all the stock, the petitioner, Irving Bartel, received an account reflecting disbursements that had been made to him during the preceding 11 years and that had been treated by him and the corporation as loans for income tax purposes. The issue to be decided is whether, in computing...
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