Memorandum Findings of Fact and Opinion
JOHNSTON, Commissioner:
The respondent has determined a deficiency of $996.23 in petitioner's Federal income tax for the taxable year 1967. The issues for decision are (1) whether petitioner is entitled to a non-business bad debt deduction of $5,366.82 in 1967 under the provisions of section 166(d) (1)(B) of the Internal Revenue Code
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