Respondent determined a deficiency in petitioner's income tax of $11,816.48 for the year 1947 by disallowing a bad debt deduction claimed in 1949 and effective for 1947 because of a net operating loss deduction. The issues are: (1) Whether the advances by petitioner were loans or capital contributions; (2) if they were loans, whether petitioner proved that they became worthless in 1949; and, if so, (3) whether they are "business" or "non-business" debts within the meaning...
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