Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in the petitioners' income taxes for the years 1951, 1952 and 1953, in the amounts of $439, $1,082.50 and $1,459.08, respectively. Certain adjustments made by the Commissioner were either uncontested or conceded to be correct. We must decide whether a debt which became worthless in 1951 is a business or a non-business bad debt.
Findings of Fact
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