Respondent determined a deficiency in income tax against petitioner for the calendar year 1939 in the amount of $2,160.81. The deficiency resulted from respondent's disallowance of a deduction of $18,661.90 as a bad debt that had been so ascertained in the taxable year.
FINDINGS OF FACT.
Petitioner is a resident of New York City and filed his income tax return for 1939 with the collector of internal revenue for the second district of the State of New York...
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