OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $8,531.67 in the income tax of the petitioners for the calendar year 1943. The only issue for decision is whether a debt of $28,985.97 which became worthless in 1943 is deductible in its entirety under section 23 (k) (1), or whether it was a "non-business debt" within the meaning of that term as used in section 23 (k) (4) and, therefore, subject to the limiting provisions of that...
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