United States Tax Court.
Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in petitioner's income tax for the year 1945 of $2,605.88. This deficiency is due to the action of the Commissioner in disallowing as a deduction a bad debt loss of $10,000 which petitioner claimed on his income tax return for that year. This disallowance is explained by the Commissioner in his deficiency notice as follows:
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