Memorandum Findings of Fact and Opinion
LEECH, Judge:
This controversy involves an income tax deficiency in the amount of $92,175.60 for the calendar year 1941, only a part of which is in controversy. The sole issue is whether petitioner is entitled, in computing net taxable income, to either an ordinary or a capital loss deduction on the sale of two separate residential properties. The case was submitted upon a stipulation of facts, oral testimony and exhibits...
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