In this proceeding we are concerned with an income tax deficiency of $35,864.13 determined by respondent against petitioner for the calendar year 1941. Petitioner claims an overpayment of $16.73. Respondent disallowed a loss of $464,637.95 claimed by petitioner as a long term capital loss in connection with the retirement of 805 shares of stock in its wholly owned subsidiary, and petitioner is here contesting the disallowance.
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