Memorandum Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1973 in the amount of $1,667. The only issue for decision is whether petitioners are entitled to deduct in 1973 as a loss or bad debt the amount of $7,740 which is the same amount included in their 1969 income as Mr. Cram's pro rata share of the undistributed taxable income of South Carolina Mobile Homes, Inc. (SCMH), a subchapter S corporation...
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