Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $5,344.42 in the petitioners' income tax for the year 1947.
The only issue for decision is whether respondent erred in disallowing a farm loss claimed by the petitioners for the year 1947. The respondent's "Explanation of Adjustments" in the deficiency notice was as follows:
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