Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined a deficiency of $10,142.52 in the income tax of petitioners for 1948.
The issues presented are the correctness of the respondent's action (1) in determining that the petitioner, Eugene Reynal, is not entitled to a deduction for a business bad debt on account of two promissory notes, and (2) in determining that petitioner sustained a long-term capital loss on the disposition...
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