The Commissioner determined a deficiency in petitioner's income tax in the amount of $601.89 for the calendar year 1952. The deficiency for 1952 is due to the Commissioner's disallowance of a loss claimed on the sale of a boat which petitioner purchased in 1946 but which was never used because of the inability to secure a charter license. The petitioner claims a deduction for the difference between the purchase price of the boat in 1946 and the selling price in 1952. The...
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