Respondent determined a deficiency in income tax for petitioner and her husband (now deceased) for the taxable year ending December 31, 1949, in the amount of $450.26.
The issue before us grows out of disallowance by respondent of a deduction of $2,000 which petitioner and her husband had taken on their return for 1949. The deduction was taken on the theory that the amount in question represented a debt which had become worthless in the year in question.
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