Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners' income taxes for the years 1952 and 1953 in the respective amounts of $18,072.10 and $4,522.74. Petitioners, in addition to controverting the determinations, claim that they overpaid their taxes for the calendar year 1953.
The issues are whether certain loans and related rights acquired by subrogation, and which admittedly became worthless...
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