Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax determined against Thomas C. Wilwerth (hereinafter referred to as petitioner) in the amount of $1,645.21 for the taxable year 1947.
The sole issue to be decided is whether petitioner is entitled to claim, on his individual income tax return for 1947, a loss in the amount of $6,045.38 sustained from the operation of certain rental property, title to which was held...
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