The Commissioner has determined a deficiency in income tax for 1950 in the amount of $4,188.66. The petitioner contests the determination and claims an overpayment of tax in the amount of $11.34. The only issue remaining is the propriety of respondent's treatment of a $10,000 debenture which became worthless in 1950 as a loss sustained from the sale of a capital asset rather than as a cost of goods sold, as an ordinary and necessary business expense, or as a business loss...
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