Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax for the calendar years 1944 and 1945 in the respective amounts of $5,669.45 and $2,819.12, and five per cent negligence penalties in the respective amounts of $283.47 and $140.96.
The issues for each taxable year are whether respondent erred: (1) in disallowing deductions for business expenses, contributions, and bad debts; (2) in including in petitioner's income certain...
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