Memorandum Findings of Fact and Opinion
CHABOT, Judge:
Respondent determined deficiencies in Federal individual income tax against petitioners for 1971, 1972 and 1973 in the amounts of $4,053.39, $6,369.62, and $18,448.14, respectively.
After respondent's concession of one issue, the issue for decision is whether net transfers to petitioners from their wholly-owned corporation were loans (not taxable to petitioners in the years before the Court)...
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