Memorandum Opinion
HILL, Judge:
This proceeding is for the redetermination of a deficiency in income tax for the year 1939 in the amount of $26,625.93. The issue involves a bad debt deduction in the amount of $100,000, claimed by petitioner and disallowed by respondent.
[The Facts]
Petitioner is a resident of Philadelphia, Pennsylvania, and filed her individual income tax return for the year 1939 with the collector of internal revenue...
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