Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioner's income tax for the taxable year 1953 in the amount of $128,118.62. The disputed portion of this deficiency results from respondent's disallowance of deductions for losses resulting from an alleged debt which petitioner claims became partially worthless during the calendar year 1953 and petitioner's investment in some railroad stock which petitioner contends became wholly worthless...
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