Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in petitioner's income tax for the year 1943 of $4,400.91 and a deficiency in petitioner's excess profits tax of $176.73. The deficiency is due to the disallowance of a bad debt deduction of $17,363.38. The explanation which the Commissioner made in his deficiency notice for the disallowance was as follows:
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