Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax of the petitioner for the taxable years 1952 and 1953, as successor by merger to Elbeco Realty Corporation, in the amounts of $6,841.92 and $102,674.34, respectively. The issue presented is whether Elbeco was entitled to a deduction of $390,000 claimed by it as a partial bad debt in its 1953 income tax return. Dependent upon the decision of this issue...
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