FEATHERSTON, Judge:
Respondent determined a deficiency of $35,122.93 in petitioner's Federal income tax for the fiscal year ending February 28, 1967. The sole issue for decision is whether petitioner's unrecovered advances to another corporation, in which it held stock, gave rise to a capital loss deduction, or whether these amounts are deductible from ordinary income as either an ordinary and necessary business expense under section 162,
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