Memorandum Opinion
STERNHAGEN, J.:
A deficiency of $2,187.69 in 1938 income tax resulted from the disallowance of a deduction for loss in the sale of securities.
The petitioners are husband and wife and reside in Syracuse, New York. The wife in 1929 pledged certain shares with The Salt Springs National Bank of Syracuse as collateral security upon a demand note for $40,500, and the note contained the usual authorization upon default to sell the collateral...
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