Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioner's income tax for 1945 in the amount of $21,866.37. The issue is whether the respondent properly disallowed a business bad debt deduction in the taxable year 1945 on the ground that the advances made by the petitioner were capital contributions. In the alternative, the issue is whether the advances were nonbusiness bad debts under section 23(k)(4) of the Internal Revenne Code...
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