Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
The respondent determined deficiencies in income tax for the taxable years ended December 31, 1951 and 1952 in the amounts of $2,329.16 and $2,927.36, respectively.
The amended petition assigns both directly and alternatively a large number of errors which may be summarized as follows:
(a) The respondent erred in disallowing the deduction of a loss in the amount of $39,515.54 sustained...
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