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EDWARD G. JANEWAY v. COMMISSIONER

Docket Nos. 110034, 111589.

2 T.C. 197 (1943)

EDWARD G. JANEWAY AND ELINOR W. JANEWAY (HUSBAND AND WIFE), PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. ROBERT McC. SHIELDS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 22, 1943.

Attorney(s) appearing for the Case

Harrison Lillibridge, Esq., for the petitioners.

William G. Ruymann, Esq., for the respondent.

These proceedings, duly consolidated, involve the redetermination of income tax deficiencies for the year 1939 in the following amounts: Docket No. 110034, $438.04; Docket No. 111589, $1,860.37. In Docket No. 110034, the petitioners allege an overpayment in the amount of $3.51.

The single question for decision is whether the petitioners are entitled to deductions for the full amounts of certain worthless promissory notes owing to them, or whether only a percentage...

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