Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax for the taxable year 1941, in the amount of $326.68.
The deficiency arose as a result of the disallowance by the Commissioner of the sum of $4,228.90, deducted from gross income and claimed by petitioner as an allowable bad debt deduction under section 23(k) of the Internal Revenue Code.
Petitioner has conceded that an item amounting to $500 paid for attorneys...
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