Memorandum Findings of Fact and Opinion
WILLIAMS, Judge
The Commissioner determined a deficiency in Federal income tax for petitioner's taxable year ended December 31, 1979 of $10,002.86 in docket No. 17481-84, and a deficiency in Federal income tax for petitioners' taxable year ended December 31, 1979 of $2,136.06 in docket No. 17482-84. The issues this Court must decide are (1) whether a loan to an electing small business...
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