The Commissioner determined deficiencies in the income tax of the petitioners of $15,452.86 for 1948 and $16,683.98 for 1949. The petitioners have conceded the correctness of the deficiency for 1948 and all issues relating to 1949 except whether they are entitled to a deduction under section 23 (e) for a loss instead of a deduction for a nonbusiness bad debt under section 23 (k) (4).
FINDINGS OF FACT.
The petitioners, husband and wife, filed joint returns...
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