Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined a deficiency of $7,341.92 in petitioner's income tax for 1966. After petitioner's concession with respect to receipt of $124 of dividend income, the three following issues remain: (1) whether a debt which became worthless in 1966 was a nonbusiness bad debt as defined by section 166(d);
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