OPINION.
BLACK, Judge:
The Commissioner has determined deficiencies in petitioner's income tax for the years 1954 and 1955 in the amounts of $2,783.18 and $2,942.32, respectively. The deficiencies for 1954 and 1955 are due to one adjustment made by the Commissioner which is explained in the deficiency notice as follows:
(a) For the years 1954 and 1955 you realized taxable income, before deduction, for bad debts in the amounts of $9,763.04...
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