Memorandum Findings of Fact and Opinion
RAUM, Judge:
The petitioners, residents of New York, New York, filed a joint income tax return for the year 1942 with the collector of internal revenue for the fourteenth district of New York. On the return there was claimed a deduction for a worthless debt in the amount of $46,289.06. The Commissioner refused to allow the deduction. By reason of the forgiveness feature of the Current Tax Payment Act of 1943, the Commissioner...
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