MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined a deficiency of $486,355 in petitioner's Federal income tax (tax) for the taxable year ended January 30, 2000 (year at issue).
The only issue for decision is whether the $1.5 million ($1.5 million at issue) that petitioner received from its principal supplier during the year at issue constitutes a loan that is not includable in its gross income. We hold that it does not...
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