Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax of the petitioner for 1945 in the amount of $8,405.82. The only issue for decision is whether a debt in the amount of $120,426.10 which became worthless in 1945 was a business or non-business bad debt within the meaning of section 23 (k) of the Internal Revenue Code.
Findings of Fact
The petitioner was engaged in the practice of law from 1912 through...
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