Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies of $13,253.22 and $12,859.30 in petitioners' Federal income taxes for 1975 and 1976, respectively. The only issue is whether petitioners realized taxable income as a consequence of interest-free loans made to petitioner-husband by a corporation of which he was a shareholder.
All the facts have been stipulated and are found accordingly.
Petitioners, Milton...
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