OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $24,542.51 in income tax of the petitioners for 1950. All of the facts of record, except as to the value of the Narragansett property before and after the storm, have been stipulated.
The first issue for decision is whether the Commissioner erred in holding that the expiration without exercise of an option to purchase stock resulted in a short-term capital loss of the $50...
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