Memorandum Findings of Fact and Opinion
JOHNSON, J.:
Respondent determined deficiencies in petitioners' income tax for 1948 and 1949 in the amounts of $112,715.34 and $72,404.66, respectively. The following issues are presented in this proceeding:
(1) Was petitioners' gain from the sale of an oil payment in 1948 ordinary income or capital gain?
(2) Were petitioners entitled to certain claimed bad debt deductions for 1948 and 1949?
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