The respondent determined a deficiency of $3,733.86 against the petitioner for the calendar year 1947, on the ground that petitioner's loss on the liquidation of a partnership of which he was a member was not an ordinary loss but was a loss from the sale or exchange of a capital asset within the meaning of section 117, Internal Revenue Code of 1939. Subsequently, by leave of the Court, the respondent amended his answer to claim an increased deficiency of $4,419.90. The basis...
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