Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in the income tax of petitioner for the period January 1, 1962 through September 5, 1962 in the amount of $6,333.73. The principal issue is whether advances made by petitioner's decedent to a wholly owned corporation were business bad debts deductible in the taxable period ending September 5, 1962. Another issue litigated by the parties is whether the gross income of petitioner's decedent...
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