These consolidated proceedings involve deficiencies in income tax for the calendar year 1944 of $1,177.85 for George Aftergood and $1,177.84 for his wife, Kathryn Aftergood.
The issue to be decided is whether the compromise settlement of a $5,000 note for the sum of $2,000 resulted in (1) a taxable gain of $3,000 as respondent determined, (2) a loss of $2,000 as petitioner reported, or (3) a nonbusiness bad debt.
Some of the facts were stipulated.
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