ATKINS, Judge:
The respondent determined a deficiency in income tax for the calendar year 1951 in the amount of $60,171.69. The primary question at issue is whether the petitioner is entitled to a business bad debt deduction in the amount of $118,503.10 under section 23 (k) (1) of the Internal Revenue Code of 1939. Alternatively, the petitioner contends that to the extent of $100,000 this amount represented payment of his liability as endorser on a note and...
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