Memorandum Findings of Fact and Opinion
RAUM, Judge:
The correctness of the Commissioner's determination of a $1,024.93 deficiency in income tax turns upon whether petitioner is entitled to a deduction under Section 23 (e) (3) of the Internal Revenue Code for an alleged loss resulting from damages to certain antique chinaware shipped from South America to the United States.
Petitioner is a resident of New York City. In 1946 he was in Brazil, and...
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