The respondent determined a deficiency of $20,939.21 in the income tax of the petitioner for the year 1946. The issue for our decision is whether a loss in the amount of $24,250 sustained by the petitioner in 1946 is deductible in full under either of sections 23 (e) (1), 23 (e) (2), or 23 (k) (1) of the Internal Revenue Code, as contended by the petitioner, or as a nonbusiness bad debt under the provisions of section 23 (k) (4), as determined by the respondent.
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