Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $3,112 and $31,368 in petitioner's Federal income taxes for 1979 and 1980, respectively. The deficiencies resulted from disallowance of certain travel and entertainment expenses claimed by petitioner for each year and a bad debt deduction claimed by petitioner for 1980. All section references are to the Internal Revenue Code in effect for the years at issue, and all...
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