Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1955 in the amount of $41,502.23. The issues for decision are:
(1) Whether petitioners are entitled to a bad debt deduction in 1955 of $3,000 as a result of a loan which Ve-Shuen Hsiang had made to a person who was engaged in business in New York, New York as Madame Lee-Sun, becoming worthless in that year.
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