- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011