Supplemental Memorandum Opinion
HILL, Judge:
This proceeding was heard on the merits at Philadelphia, Pa., on September 15, 1942, at which time evidence was adduced by both parties. The sole issue was whether petitioner was entitled to a deduction for an alleged bad debt in the amount of $100,000, which had been disallowed by respondent. This adjustment by respondent, together with others not in controversy, resulted in his determination of a deficiency...
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