Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1957, 1958, 1959 and 1960, in the respective amounts of $11,710.77, $1,094.00, $1,355.73 and $4,555.87. The issue for decision is whether petitioner is entitled to a bad debt deduction in the taxable year 1960 in the amount of $56,450 resulting in a net operating loss in that year which is an operating loss carryback...
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