Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax against petitioner as follows: For 1938, $6,327.95; and for 1939, $9,882.02.
It was stipulated that the following amounts are properly excludable from petitioner's income for the years designated as representing non-taxable bad debt recoveries: For 1938, $14,587.49; and for 1939, $10,781.38. Effect to this stipulation will be given under Rule 50.
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