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After concessions,2 the sole issue remaining for decision is
whether petitioners are entitled to a bad debt deduction of
$182,451.03 for the 1988 taxable year.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. Petitioners resided in Acton,
Massachusetts, at the time they filed their petition.
Petitioners are the owners of Stow Laboratories, Inc. (SLI),
a closely held Massachusetts corporation with its principal place
of business in Hudson, Massachusetts. SLI has been engaged in
the manufacturing and sale of electrical equipment since it was
incorporated on April 4, 1973. Mr. Kadlec is the president and
treasurer of SLI as well as a director and full-time employee.
He owns 80 percent of SLI's stock. Mrs. Kadlec is the vice
president, clerk, and a director, and she owns the remaining 20
percent of SLI's stock. From 1973 to the date of trial,
petitioners made capital contributions to SLI in the total amount
of $250.
2At trial, petitioners conceded the addition to tax pursuant
to sec. 6651(a)(1) for delinquent filing of their 1988 Federal
income tax return.
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