Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency of $81,501 in petitioners' Federal income tax for 1981 and an addition to tax of $20,375 under section 6651(a)(1).
After concessions, the issues remaining for decision are: (1) whether petitioners are entitled to an $85,000 business bad debt deduction claimed on Schedule C of their 1981 joint income tax return, and (2) whether petitioners...
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