MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
For 1996, respondent determined a deficiency in petitioner's Federal income tax of $31,873.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue.
The issue for decision is whether certain payments petitioner made to its shareholders in 1996 should be treated as deductible interest on shareholder loans or as nondeductible dividends...
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