Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $6,488.46 in petitioners' Federal income tax for the year 1963. In their amended petition filed herein on May 17, 1971, the petitioners claim an overpayment of income tax for 1963 on the ground that they are entitled to a business, rather than nonbusiness, bad debt deduction for that year.
The issues for decision are: (1) Were advances totaling $29,800 made...
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