Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in income taxes due from Merlite Industries, Inc., and its subsidiary, Merlite Commercial Corp., for the fiscal years ended July 31, 1966, and July 31, 1967, in the amounts of $2,097.42 and $23,948.69, respectively.
The issues for our decision are as follows:
1. Whether petitioner is entitled to bad debt deductions under section 166
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