Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined deficiencies in the income tax of the petitioners of $18,645.12 for 1964 and $2,496.00 for 1965. The issues for decision are (1) whether the petitioner, Doris Prizant, realized a gain, which is taxable as ordinary income, as a result of her loaning money to a corporation and being repaid more than she loaned; and (2) whether the petitioners are entitled to treat the loss on...
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