SIMPSON, Judge:
The respondent determined a deficiency of $2,172.30 in the Federal income tax of the petitioners for the year 1966. There are two issues for decision: (1) Whether a loan by Electronics, a limited partnership, was created or acquired in connection with its trade or business, and (2) whether the failure to perform on a guaranty of such loan gives rise to a loss deductible under section 165 of the Internal Revenue Code of 1954.
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