Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1966 in the amount of $2,077.17.
The issue for decision is whether petitioner's wholly-owned corporation filed a valid election to be taxed as a small business corporation under subchapter S so as to entitle petitioner to deduct the loss sustained by the corporation in 1966 and, in the alternative, whether...
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