Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for taxable years ending December 31, 1971, and December 31, 1972, in the respective amounts of $27,056.26 and $25,803.78. After concessions, the issues for decision herein are as follows: (1) Whether payments made by petitioner, Stuart M. Modell, during taxable years 1971 and 1972 to lenders and trade creditors of F&J Derusting...
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