Memorandum Findings of Fact and Opinion
The respondent determined a deficiency against petitioner in income tax for the calendar year 1937 in the sum of $630.61. The sole issue is whether a payment of $10,000 on notes held by the Union National Bank of Lowell, Massachusetts, during 1937 constituted a deductible loss.
Findings of Fact
We adopt as a part of our findings of fact the stipulation of the parties, which is substantially as follows:
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