The Commissioner has determined, for the calendar year 1955, a deficiency in income tax of $1,813.06 and an addition to tax of $41.82 under section 6654, I.R.C. 1954. The only issue is whether an amount of $8,250, which petitioners claimed on their return as a bad debt deduction, was a nonbusiness bad debt deductible under section 166, I.R.C. 1954, only to the extent of a net capital loss.
FINDINGS OF FACT.
The petitioners are husband and wife and are residents...
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