Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in the petitioners' income tax for the year 1952 in the amount of $2,817.14. The sole issue for decision is whether the petitioners sustained a business bad debt or a non-business bad debt, or alternatively a business loss, as a result of certain advances and loans to a magazine publisher becoming worthless in 1952.
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