Respondent determined deficiencies in petitioners' income tax for the calendar years 1951 and 1952 in the amounts of $2,480.10 and $2,641.28, respectively.
The principal issue is whether loans of $25,000 and guaranty payments of $1,000 are deductible as losses under section 23 (e) of the Internal Revenue Code of 1939 or as bad debts under section 23 (k) and, if the latter, whether the debts are deductible during 1952 as business bad debts under section 23 (k) (1)...
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