The respondent determined a deficiency in income tax against petitioners for the year 1954 in the amount of $4,254.47. The question for decision is whether a bad debt loss claimed by petitioners as a deduction on their 1954 return was a nonbusiness rather than a business bad debt, and is to be treated, therefore, as a short-term capital loss.
FINDINGS OF FACT.
Some of the facts have been stipulated and are found as stipulated.
Petitioners are husband...
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