Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax of the petitioners for the year 1945 in the amount of $3,198.59. The issues are:
1. Did the petitioners sustain a deductible loss in the year 1945 because of the sale of certain property in Florida for delinquent taxes?
2. If a loss was sustained in 1945 from the sale of that property for delinquent
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