Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies of $225.90 and $4,302.51 in the income tax of the petitioners for 1942 and 1944, respectively. The only issues are whether the respondent erred (1) in determining that an amount of $127,000 deducted by the petitioners in their 1943 return was a nonbusiness bad debt allowable as a short-term capital loss instead of allowing the amount in its entirety as a bad debt...
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