Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a deficiency in petitioner's 1967 Federal income tax in the amount of $23,844.07.
Petitioner claimed a $169,334 net operating loss deduction in its corporate income tax return for the calendar year 1967. Respondent disallowed $115,113 of the deduction, representing deductions claimed for additions to a bad debt reserve for the calendar years 1964, 1965 and 1966 of an acquired...
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