Memorandum Findings of Fact and Opinion
OPPER, Judge:
A deficiency in income and victory tax for the year 1943 of $94.39 is in controversy in this proceeding. The issue is the deductibility as a bad debt of an amount of $5,598 (reduced to $1,000 by reason of Internal Revenue Code, section 117 (d) (2)) of an advance originally made in 1903 and claimed to have become worthless in the present year.
Findings of Fact
Petitioner filed his tax...
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