Memorandum Findings of Fact and Opinion
WILBUR, Judge:
In these consolidated cases, respondent determined a deficiency of $12,994.55 in petitioners Daniel J. and Madelyn Halpern's 1974 Federal income tax and a deficiency of $2,734.08 in petitioner McDevitt's 1974 Federal income tax.
Concessions having been made by the parties, the issues remaining for decision are: (1) whether petitioners' payments on their guarantee of H.M. & A's corporate debt...
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