Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency of $2,265.97 in income taxes of the petitioners for 1960. Petitioners have conceded that a charitable-contribution deduction taken on their 1960 income tax return in the amount of $4,594.55 was improper. Petitioners contend, however, that $3,816.79 of the amount disallowed as a charitable deduction was a properly deductible nonbusiness bad debt in 1960. Thus, the only...
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