Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies in income tax of the petitioners as follows:
Docket No. Year Deficiency 37413 1948 ........... $7,567.54 38407 1949 ........... 7,769.26
The issues presented for determination are the correctness of the respondent's action (1) in disallowing a deduction taken for 1948 for a non-business bad...
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