Memorandum Findings of Fact and Opinion
This proceeding is for the redetermination of a deficiency in income tax for the calendar year 1943 in the amount of $5,625. The question for decision is whether a debt of $25,000, which became worthless in 1943, is deductible in its entirety under section 23(k)(1), or is a "non-bunsiness debt" subject to the limitations of section 23(k)(4) of the Internal Revenue Code.
In the deficiency notice respondent disallowed...
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