OPINION
ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1960 in the amount of $79,895.26. The petitioner having conceded one of the issues, the only issue remaining is whether the respondent erred in determining that the balance in petitioner's reserve for bad debts at the time in 1960 that the petitioner sold its assets, including its notes and accounts receivable, constituted ordinary income to the petitioner...
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