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not claim a deduction for a bad debt, pursuant to section 166(a).
We have considered all of the contentions and arguments of the
parties that are not discussed herein,8 and we find them to be
without merit, irrelevant, or moot.
To reflect the foregoing,
Decision will be entered
for respondent.
8Having held that petitioners have failed to show that a
bona fide debt exists, we need not decide whether the claimed
debt became worthless in 1997.
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