Memorandum Findings of Fact and Opinion
The respondent determined income tax deficiencies for the taxable years 1952 and 1954 in the respective amounts of $15,501.30 and $3,481.44.
The question for the year 1952 is whether a loss of $33,317.51 is a bad debt incurred in trade or business within the meaning of section 23(k) of the Internal Revenue Code of 1939, or, in the alternative, whether the amount represented an equity contribution to the capital of...
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