Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the amount of $2,078.90 in petitioner's income tax for 1952. The deficiency resulted from the disallowance by respondent of a deduction in the amount of $12,000 claimed by petitioner with the following explanation: "Loan to Wayside Food Shop, Inc. Corp. dissolved & debt uncollectable in 1952." Respondent, in the notice of deficiency, explained his disallowance...
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