Memorandum Findings of Fact and Opinion
BAAR, Judge:
The respondent determined deficiencies in the income tax of the petitioner for the years 1946 and 1947 in the respective amounts of $1,149.60 and $655.51.
The sole issue presented for our decision is whether the petitioner sustained a deductible loss on the sale of certain shares of the common and preferred stock of Philadelphia Memorial Park on July 12, 1946.
Findings of Fact
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