Respondent determined a deficiency in petitioner's income tax liability for the calendar year 1945 in the amount of $524.41.
The deficiency resulted principally from respondent's disallowance of a bad debt claimed by petitioner in the amount of $3,147.29. Respondent treated the transaction as a long term capital loss and allowed 50 per cent thereof, pursuant to section 117 of the Internal Revenue Code, in his computation of the deficiency. Other adjustments made by...
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