Memorandum Findings of Fact and Opinion
This proceeding involves an income tax deficiency of $10,986.02 for 1944. Petitioners claim an overpayment of $2,560.70, the total amount of tax shown on their return. The question in issue is whether a loss on the conveyance of a number of parcels of real estate to a mortgagee bank in satisfaction of petitioners' indebtedness occurred in 1941, as respondent has determined, or in 1942, as petitioners contend, and whether such...
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