Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $431.92 in income tax for the year 1947. The petitioner claims an overpayment in the amount of $1,491.89, the entire amount of the tax paid for that year.
The only issue for decision is whether a loss of $76,121.11 sustained in 1947 was an ordinary business loss deductible in full under section 23(e) of the Internal Revenue Code of 1939 or a capital loss under section 23...
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