Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $20,830.76 in the petitioner's income tax liability for the year 1943. The petitioner claimed an over-payment of $23,719.02 in his income taxes for that year.
The sole issue now in controversy is whether or not the petitioner is entitled to the deduction of $432,669.22 as a worthless debt under the provisions of section 23 (k) (1) of the Internal Revenue Code. A second issue...
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