Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in petitioner's income tax of $5,965.22 and $7,782.12 for the taxable years 1946 and 1947, respectively. The issues for determination are whether petitioner's business income exceeded the amounts reported in 1946 and 1947, and whether respondent was correct in disallowing petitioner a capital loss of $1,000 on the sale of stock in 1947.
Findings of Fact
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