Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioners' income taxes for the years 1960 and 1961 in the amounts of $4,028.11 and $6,802.48, respectively.
The asserted deficiencies result from respondent's disallowance of claimed deductions for business bad debt losses. Three questions are presented for decision:
1. Did losses sustained in 1963 by petitioner which resulted from his payment...
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