Memorandum Findings of Fact and Opinion
Respondent determined a deficiency for the year ended December 31, 1948, on the basis of disallowance of a loss on the disposition of certain business assets. Petitioners had deducted the loss as a net loss carry-over from the year 1946. The disallowance was made on the ground that the loss was not attributable to the operation of a trade or business regularly carried on by petitioner and, therefore, was not allowable as a...
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