Memorandum Findings of Fact and Opinion
FISHER, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1954 in the amount of $2,498.59.
The sole issue presented is whether a loss sustained by petitioners from an unpaid loan is to be deducted as a business bad debt or as a nonbusiness bad debt.
Findings of Fact
Some of the facts have been stipulated and, to the extent so stipulated, are incorporated...
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