Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined an income tax deficiency of $128,553.91, for petitioner's fiscal year ended August 31, 1955. Part of the deficiency results from respondent's disallowance of a deduction of $591,603.68 for a partially worthless debt under section 166(a)(2), 1954 Code. The chief question is whether cash advances of petitioner to Patroon Broadcasting Co., Inc., in which petitioner is the controlling...
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