TIETJENS, Judge:
The Commissioner determined a deficiency in the petitioner's 1951 income tax in the amount of $6,707.55. There are two issues for our decision: (1) Whether the petitioner sustained an abandonment loss in 1951 as a result of its permanently discarding certain title abstract records it had purchased in 1929 from the Dane Abstract of Title Company; and (2) what portion of the petitioner's 1951 microfilming expenses represented the cost of microfilming...
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