Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined a deficiency in income tax for 1945 in the amount of $6,295.02, arising out of the disallowance of a claimed long-term capital loss carry-over from 1944. The loss arose from a sale of real property in 1944. The amount is not in dispute. The sole issue is whether the loss was capital or ordinary.
[The Facts]
Petitioner is an individual residing at 316 Lexington...
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