OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency in income tax of the petitioner for 1951 in the amount of $6,205.60. One of the adjustments which he made was to add to income "Losses from sale of mixed metal $8,540.49." He explained that adjustment as follows:
(c) In your income tax return for the year ended December 31, 1951, you reduced the long term capital gains to be taken into account by the amount of $8,540.49 which...
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