Memorandum Findings of Fact and Opinion
KERN, Judge:
The present case comes before us on respondent's findings of a deficiency in petitioner's income tax of $805.78 for the year 1939. The only question is whether petitioner may take as a bad debt deduction in the year $12,000, representing his advances to a bank which became insolvent. There is no controversy on the facts and so much as need be given will be set out.
[The Facts]
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