Memorandum Findings of Fact and Opinion
SWIFT, Judge:
In a statutory notice dated March 9, 1984, respondent determined a deficiency in petitioner's 1980 Federal income tax liability in the amount of $167,547.
After substantial concessions by the parties, the sole issue remaining for decision is whether cash payments of $108,980.17 from a closely held corporation to petitioner and his former wife were bona fide loans or taxable dividends.
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