Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves a deficiency of $24,883.86 in income tax for 1940, resulting, in part, from the disallowance by respondent of a deduction of $383,734.40 for a loss alleged to have been sustained upon the surrender of title to certain tracts of land. The only issue involved herein is whether the disallowance of the deduction was proper. The parties...
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