Memorandum Findings of Fact and Opinion
SMITH, Judge:
These proceedings, consolidated for hearing, are for the redetermination of deficiencies in income tax for 1940 of $1,326.52 and $2,648.02, respectively. The question in issue is whether the petitioners are entitled to bad debt deductions in the computation of taxable net income for 1940 or did they sustain capital losses limited by the provisions of section 117 (d) I. R. C., as amended by section 212...
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