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guarantee payments are not includable in petitioner’s income in
1993 because those payments were a loan.
As we have found that petitioners are not liable for the
deficiency, whether the period of limitations expired for the
1993 taxable year is moot.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not herein
discussed, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decision will be
entered for petitioners.
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Last modified: May 25, 2011