Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined a deficiency of $40,026 in petitioners' Federal income tax for 1986. There are two issues for decision. The first is whether petitioners are entitled to deduct $100,000 as a loss on section 1244 stock. All section references are to the Internal Revenue Code. The second is whether petitioners are entitled to deduct the amount paid under certain loan guarantees as an ordinary and...
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