Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in income tax against petitioner Arthur Rubel in the amounts of $490.31 for 1946 and $2,069.72 for 1947 and against petitioner Sarah Rubel in the amounts of $508.08 for 1946 and $2,098.21 for 1947. The deficiencies resulted principally from the respondent's disallowance of a $10,000 loss deduction from the petitioners' community income for 1947.
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