Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax for the taxable year 1973 in the amount of $10,194.65. Concessions having been made, the only remaining issue to be decided is whether payments made by petitioner under a guarantee of a corporate debt are deductible as business bad debts or as nonbusiness bad debts, pursuant to section 166(a)
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