MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for its fiscal tax years ended September 30, 1991, 1992, and 1994, of $216,552, $225,336, and $8,190, respectively. The sole issue for our consideration is whether bad-debt deductions taken in 1994 are allowable under section 166.
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