Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency in petitioner's 1990 Federal income tax in the amount of $38,706, an addition to tax pursuant to section 6651(a)(1) in the amount of $5,806, and an accuracy-related penalty pursuant to section 6662(a) in the amount of $7,741.
The issues for decision are: (1) Whether petitioner is entitled to a claimed deduction for a business bad debt in the amount of $175,559...
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