Memorandum Findings of Fact and Opinion
DISNEY, J.:
This proceeding involves a deficiency in income tax for the calendar year 1937 in the amount of $32,733.96. The sole issue for decision is whether the petitioner was entitled to deduct the sum of $76,900 as a debt ascertained to be worthless and charged off within the taxable year.
The proceeding has been submitted upon evidence adduced at the hearing and upon stipulations of facts which we adopt...
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