Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency in petitioners' income tax for the taxable year 1969 in the amount of $1,732.14. The issues are: (1) Whether a $20,000 advance made by petitioner represented a bona fide loan or a contribution to capital; and (2) whether amounts paid under an indemnity agreement and a loan agreement are deductible under section 166
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