Memorandum Findings of Fact and Opinion
The Commissioner has determined a deficiency in the income tax of petitioners for the calendar year 1959 in the amount of $2,969.24. The deficiency is due to the disallowance of a deduction taken on the joint income tax return of petitioners for the year 1959 as follows: "(a) Bad debts $10,084.32." This adjustment is explained in the deficiency notice as follows:
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