Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $11,043.16 in the income tax of Frank A. Moorshead, deceased, and Hannah W. Moorshead for 1948. The only issue presented is the correctness of respondent's action in disallowing a deduction of $27,851.59 taken as a business bad debt on account of sums advanced to a client or paid for his account in 1939 and all of which remained unpaid at the time of the...
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