The Commissioner has determined a deficiency in petitioner's income tax of $3,554.98 for 1947. The deficiency is due to one adjustment to the net income as reported by petitioner on his return for 1947. That adjustment is "(a) Deduction for loan to Warmont Holding Co. Inc. disallowed $7,000.00." The adjustment is explained in the deficiency notice as follows:
(a) It has been determined that an amount of $7,000.00 claimed in your return as a loan to Warmont Holding...
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