Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in petitioner's income tax for the calendar years 1952 and 1953 in the respective amounts of $252.93 and $327.77.
In petitioner's income tax return for the year 1952 she claimed a deduction in the amount of $1,000 as a long-term capital loss, explained in Schedule D as "Promissory Notes Found to be non-collectible During the year 1952," in the amount of $5,725 of which $1,000 was...
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