MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine deficiencies of $35,742 and $26,756 in his 1995 and 1996 Federal income taxes, respectively. Following concessions,
1. Whether the notice of deficiency is "arbitrary". We hold it is not.
2. Whether petitioner may deduct a forgiven debt in the amount claimed on his 1995 tax return. We hold he may.
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