OPINION.
SMITH, Judge:
This proceeding involves a deficiency of $3,450 in petitioner's income tax for 1941. The only question in issue is whether petitioner is entitled to a loss deduction on the sale of a membership certificate in the New York Coffee and Sugar Exchange, Inc.
The proceeding was submitted on the following stipulation of facts:
1. Petitioner, FREDERICK R. HORNE, is a resident of the City and State of New York, and filed...
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