Memorandum Findings of Fact and Opinion
IRWIN, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax as follows:
Year Deficiency 1966 ........... $3,207.76 1967 ........... 9,345.00 1969 ........... 200.00
The principal issue is whether losses sustained in connection with a loan made by petitioner Leo Fitzpatrick II are deductible under section 166, I.R.C.,
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