Memorandum Findings of Fact and Opinion
SMITH, Judge:
The petitioner protests the respondent's determination of a deficiency in income tax for 1936 in the amount of $10,151.26 plus a 25 percent penalty amounting to $2,537.82 for failure to file a return. The questions in issue are whether the petitioner is entitled to deduct from his gross income for 1936, either as a bad debt or as a loss, the amount of $49,000; also New York State income taxes paid in...
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