Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency of $12,640.73 in petitioner's income tax for the year 1947. A depreciation adjustment is not contested. The questions to be decided are (1) whether loans made by petitioner which became worthless in 1947 are deductible in full as business bad debts, or as business losses, or as losses on transactions entered into for profit, or whether they are deductible solely at capital...
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