Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for the taxable year 1953 in the amount of $2,513.42.
The issue for decision is whether the amount of $6,462.47 was a business bad debt deductible under section 23(k) of the 1939 Code, or as a loss incurred in trade or business, not compensated for by insurance or otherwise, and deductible under section 23 (e)(1) of the 1939 Code.<...
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