OPINION.
DISNEY, Judge:
The controversy here involves income and declared value excess profits taxes for the calendar year 1935. Deficiences were determined as follows: in income tax, $853.57; in declared value excess profits tax, $310.39. The petitioner claims overpayment of $6,974.07. The only issue presented is whether petitioner is entitled in the taxable year to a deduction of $44,475.35 as a bad debt, or as a loss. A stipulation of facts was...
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