Respondent determined a deficiency in income tax for the year 1945 in the amount of $13,403.21. The sole issue is whether petitioners are entitled to a deduction of $31,839.43 or any part of such amount as a loss under section 23 (e) (1) or (2) of the Internal Revenue Code or as a bad debt under section 23 (k) (1) of the Code for payments made on a promissory note to a bank dated May 5, 1932, in the amount of $62,500 on which note Ernest Schwehm (hereinafter referred to as...
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