MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated July 3, 2003, respondent determined deficiencies in, and penalties related to, petitioner's 1998, 1999, and 2000 Federal income taxes. After concessions by respondent, the remaining issues for decision are whether: (1) The cash transfers to petitioner were loans or capital investments; and (2) petitioner is liable for section 6662
FINDINGS...
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