Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies of $701.74 and $9,121.14 in declared value excess-profits tax and excess profits tax, respectively, determined against the petitioner for its fiscal year ended April 30, 1946. The respondent determined an over-assessment of $676.20 in income tax for such year.
The only issue is whether the amount of $10,632.35 was a properly deductible bad debt under section 23(k)(1) of the 1939...
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