Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable years ended March 31, 1953 and March 31, 1954, in the respective amounts of $40,063.22 and $716.56. Among the several adjustments made by respondent, the sole item contested by petitioner is the partial disallowance of a bad debt deduction to the extent of $31,453.89 in fiscal 1954.
Findings of Fact
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