Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined a deficiency of $1,443.76 in income tax for the year 1936, consequent chiefly on his holding that a certain loss claimed by petitioner was a capital loss and limited by the provisions of section 117 (d) of the Revenue Act of 1936. Error is alleged in the respondent's failure to find that petitioner was a dealer in real estate and that the property on which the loss was claimed was held by the...
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