Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1968 in the amount of $2,115.12. Petitioners conceded at trial that they were not entitled to an ordinary deduction for certain brokerage expenses. The sole issue remaining for disposition is whether petitioners are entitled to a nonbusiness bad debt deduction under section 166 of the Internal Revenue Code of 1954...
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