Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined deficiencies in petitioner's income taxes for the years 1950 and 1951 in the respective amounts of $623.62 and $903.81.
The issues for decision are whether petitioner is entitled to deductions for bad debts: (1) A deduction for the year 1950 in the amount of $5,224.10, representing an alleged uncollectible promissory note of Richard S. Heller in said amount; and (2)...
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