Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1969 in the amount of $15,479. The issue for our decision is whether, assuming proof of worthlessness, the payment by petitioner of a certain debt entitles him to an ordinary deduction under section 166(a), as amplified in subsection (f), or whether said payment must be treated as a short-term capital loss under...
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