Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $1,791.74 in petitioners' income tax for the taxable year ending December 31, 1964 and a deficiency of $2,394.73 for the taxable year ending December 31, 1965. The sole issue is the proper treatment of bad debt losses sustained as a result of the involvement of petitioner Nate Kazdin in a landscape business.
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