Memorandum Findings of Fact and Opinion
Respondent has determined a deficiency in federal income taxes against petitioner for the year 1952 in the sum of $221.22. Petitioner has alleged errors with regard to this determination as follows: (a) the "disallowance as non-business bad debt for losses incurred in helping patients in and from mental hospitals, and (b) disallowance as non-business bad debt for an uncollectible note or contract to pay your petitioner the...
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