Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the taxable years 1977 and 1978 in the amounts of $59,302 and $12,024, respectively. Due to concessions by both parties, the sole issue for decision is whether petitioners were entitled in 1977 to business bad debt deductions in the total amount of $105,700.
Findings of Fact
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