Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in the income tax of petitioners as follows:
Year Deficiency 1951 ............ $4,560.86 1952 ............ 7,568.06 1953 ............ 5,698.82
The issue for decision is whether petitioners sustained business bad debt deductions of $83,307.66 in 1950 and $27,000.00 in 1952 resulting in net operating loss carry...
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