Memorandum Findings of Fact and Opinion
HILL, Judge:
This proceeding involves income tax deficiencies for the years 1940 and 1941 in the amounts of $795.97 and $1,764.91, respectively. Petitioner claimed deductions from gross income of $8,081.13 and $9,064.22 in each of these years as bad debts. Petitioner is a Delaware corporation and its tax returns for the years in question were filed with the collector of internal revenue at Richmond, Virginia.
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