Memorandum Opinion
ARNOLD, Judge:
This proceeding involves an income tax deficiency for 1945 in the amount of $392.44. The issue is whether respondent correctly disallowed the deduction of $1,665.34 as an addition to petitioner's bad debt reserve for the year 1945. Other adjustments made by the respondent are uncontested.
The proceeding was submitted on a stipulation of facts, the material parts of which are as follows:
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