Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined a deficiency in income tax of petitioners in the amount of $4,528.93 for the calendar year 1952. The only issue is whether a $28,650 debt owed petitioner R. A. Ziegenhorn by Kansas City-Springfield, Inc., which debt became worthless in 1952, was a business or nonbusiness debt within the meaning of section 23(k), Internal Revenue Code of 1939.
Findings of Fact
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