Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent has determined deficiencies in petitioners' 1945 income tax as follows:
Elise C. Ellis ............ $2,553.69 Crockett Ellis ............. 1,639.58
Respondent made adjustments to petitioners' net income for the year 1946, but these adjustments are not before the Court. The sole issue presented is whether the loss upon the 1947 sale of equipment and property...
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