The Commissioner determined deficiencies of $1,145.26 and $527.06 in petitioners' income taxes for 1948 and 1949, respectively. The issues raised are:
(1) Whether petitioners are entitled to a nonbusiness loss deduction, under section 23 (e) (2) of the Internal Revenue Code, for a $3,000 payment made in 1948 in settlement of petitioner Peter Stamos' liability as guarantor of notes owed by Paramount Exposition Shows, Inc. (a corporation of which he was a stockholder...
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