Memorandum Opinion
VAN FOSSAN, Judge:
Respondent determined a deficiency of $1,791.79 in petitioner's income tax for 1953 consequent on the disallowance of a deduction for a bad debt, with interest, amounting to $28,591.70. The alleged bad debt arose from a transaction in which in 1952 petitioner loaned $25,590 to a corporation in which he owned 85 per cent of the stock. The corporation in March 1953 merged with another corporation, and petitioner, as a...
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