Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
The Commissioner determined a deficiency in income tax for 1937 of $2,149.81. The question presented is whether petitioner is entitled to a bad debt deduction from 1937 gross income in the amount of $23,100 as claimed by him, or sustained a capital loss in that amount limited by the provisions of section 117 (a) and (d), Revenue Act of 1936, as determined by respondent. The case was submitted on oral...
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