Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $90,518 in petitioners' Federal income taxes for 1988 and additions to tax of $4,526 under section 6653(a)(1) and $22,613 under section 6661. After concessions, the sole issue for decision is whether petitioners are entitled to a deduction for nonpayment of a note from Mr. Goran's solely owned corporation. Unless otherwise indicated, all section references are to...
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