Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax for the calendar year 1944 in the amount of $4,062.50.
The sole issue presented is whether a nonbusiness debt in the amount of $32,968.75 became worthless in 1944 and may be deducted by petitioner in that year under section 23(k)(4) of the Internal Revenue Code.
The facts are found from a stipulation of the parties and evidence offered at the trial of the...
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