Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $13,621.14 in income tax of the petitioners for 1950. The issue for decision is whether advances by Charles were deductible in 1950 under section 23(k)(1) as worthless debts, as contended by the petitioners, as a loss on a capital contribution, as determined and allowed by the Commissioner, or as a non-business bad debt in accordance with an alternative contention raised by the Commissioner...
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