Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in the income tax of petitioners for the taxable year 1963 in the amount of $1,382.40. Because the parties have resolved certain issues raised by the pleadings, which resolutions will be given effect under Rule 50, the sole remaining issue to be decided is whether respondent has erred in disallowing a claimed nonbusiness bad debt deduction.
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