Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in income tax for the calendar years 1944, 1945, and 1946, in the respective amounts of $120.41, $1,627.58, and $7,462.09. The sole issue presented is whether the petitioners are entitled to a deduction of $48,484.28 as a business bad debt in 1946, resulting in an operating loss carry-back to 1944 and 1945. Some of the facts are stipulated. The petitioners filed...
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