The respondent has determined a deficiency of $48,397.37 in the petitioner's income tax liability for the calendar year 1943. The issue raised in this proceeding is the deductibility of sums either as a loss incurred in a transaction entered into for profit or as a worthless debt. The calendar year 1942 is involved because of the forgiveness provisions in the Current Tax Payment Act of 1943.
FINDINGS OF FACT.
The petitioner, a resident of New York, New York...
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