Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax of petitioners in the amounts of $214.20 and $233.10 for the years 1951 and 1952 respectively.
The principal issue is whether the respondent erred in disallowing deductions of $1,000 taken by petitioners in their returns for 1951 and 1952 which were based upon a loss of $4,000 claimed to have been sustained in 1951 from a non-business bad debt.
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