Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $7,684.12 in the income tax of the petitioners for 1953. He disallowed a deduction of $15,793.84 taken as a bad debt with the explanation that that amount "of worthless `advances' to B-R Cleaners, Inc., is not allowable as an ordinary loss deduction" but "the capital loss sustained therefrom is allowed subject to the limitation provided in section 117(d)." He considered $10,000...
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