Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency in income tax of $590.22 and a negligence penalty of $29.51 against Hubert D. and Ruth Horn for the calendar year 1947. The questions presented for our determination are (a) whether the petitioners sustained a bad debt loss during the calendar year 1947, and if not (b) whether they are subject to the negligence penalty provided in section 293 (a) of the Internal...
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