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HALLE v. COMMISSIONER

Docket No. 28847-81.

47 T.C.M. 703 (1983)

T.C. Memo. 1983-760

Stanley Halle and Carole Halle v. Commissioner.

United States Tax Court.

Filed December 19, 1983.

Attorney(s) appearing for the Case

Werner Strupp, 3301 New Mexico Ave. N.W., Washington, D.C., for the petitioners. Warren P. Simonsen, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

       Year                   Deficiency

       1973 ................. $31,094.00
       1977 .................  23,367.00

After concessions, the issues are (1) whether petitioners are entitled to a bad debt deduction in connection with their guaranty of a certain loan,1

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