Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in Federal income tax of the petitioner for the fiscal year ended January 31, 1950, in the amount of $1,019,900.69, not all of which is in controversy herein.
The deficiency resulted in part from the respondent's determination "that you have failed to establish that the amount of $1,014,345.20 allegedly due from The Rollman and Sons Company, constitutes a proper bad debt deduction...
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