Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner contests respondent's determination of a deficiency of $6,538.33 in income tax for 1945. One adjustment is not contested. The issue is whether petitioner is entitled to a deductible capital loss either by reason of a stock transaction during the taxable year, or, in the alternative, by reason of a capital loss carryover resulting from the fact of the worthlessness of the stock in question in...
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