Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in a statutory notice of deficiency dated November 28, 1984, determined a $23,881 income tax deficiency for petitioner's taxable year ended September 30, 1981. After concessions, the central issue for our consideration is whether petitioner, a barter exchange, acquires a basis or has an ownership interest in members' trade units so as to be entitled to: (a) Deduct, as a bad debt, uncollectible...
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