Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $23,508.49 and $10,559 in petitioners' Federal income taxes for 1981 and 1982, respectively. After concessions, the issue for decision is whether interest earned on funds allegedly loaned by petitioner Clifford Spickler (Mr. Spickler) to his minor children is taxable to petitioners.
Findings of Fact
Some of the facts have been stipulated, and the...
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