Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined deficiencies in petitioners' income tax as follows: $82,925.53 for the taxable year 1981, $336,720.00 for the taxable year 1982, and $1,216.00 for the taxable year 1984. After concessions, the issues for decision are (1) whether petitioners incurred a business or nonbusiness bad debt deduction pursuant to section 166; and (2) whether petitioners are entitled to a worthless stock...
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