Memorandum Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income tax for 1956 in the amount of $9,167.28.
The only question for decision is whether the Commissioner properly treated a claimed deduction as a nonbusiness bad debt rather than a business bad debt or as a loss deductible under the Internal Revenue Code of 1954, Sec. 165.
All of the facts are stipulated and are so found.
Petitioners, Aubrey and Lois...
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