Memorandum Findings of Fact and Opinion
OPPER, Judge:
A deficiency in 1959 income tax of $220 has been determined. The issue is whether cash advances made by petitioner (1) constituted an allowable nonbusiness bad debt under section 166(d), I .R. C. 1954, or, if not, (2) constituted a deductible loss under section 165(c), I. R. C. 1954.
Findings of Fact
Petitioner Robert L. Barnard (hereinafter referred to as petitioner) is an individual...
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