Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable years ending August 31, 1960, 1962, and 1963, in the amounts of $4,379.42, $364,879.22, and $430,503.59, respectively.
The issues for decision are whether petitioner's predecessor, Home Finance Group, Inc., is entitled to deductions for bad debts under section 166(a)(1) and losses from worthless stock under sections 165...
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