This proceeding involves an income tax deficiency for the calendar year 1944 in the sum of $148.01.
The contested issue is whether petitioner is entitled to a nonbusiness bad debt deduction to the extent of $1,000, or is limited to the amount of $750 allowed by the respondent as a long term capital loss. This issue is resolved by the answer to the question of whether, when petitioner conveyed his one-eighth interest in certain real property to Emerson Holding Corporation...
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