OPINION.
OPPER, Judge:
By this proceeding petitioner challenges respondent's determination of a deficiency of $702.20 in her income tax for the year 1939. The only item contested involves the deduction of a loss of $3,304.50 claimed on the sale of a yacht.
All of the facts are stipulated and are hereby found accordingly. They may be summarized as follows:
Petitioner filed her income tax return for the year 1939 with the collector of...
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