MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $384,753 and $251,411, for taxable years 1985 and 1986, respectively, and a deficiency of $309,459 for taxable year 1988.
After concessions, the issues for our consideration are: (1) Whether petitioners are entitled to a business bad debt deduction in 1988 under section 166
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