Memorandum Findings of Fact and Opinion
HARLAN, Judge:
This proceeding involves deficiencies declared in the income tax liability for the years 1939 and 1940 in the respective amounts of $8,061.78 and $13,627.31.
The question presented is as to the allowability of deductions taken by the petitioner of $58,100 during 1939 and $241,500 during 1940 on the ground that said amounts were written off by the taxpayer in the respective years as bad debts...
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