The respondent determined a deficiency in income tax against the petitioner for the taxable year ended May 31, 1954, in the amount of $45,424.25.
The issues for decision are (1) whether the loss sustained by the petitioner upon the sale of preferred and common stock of Ductile Iron Foundry, Inc., constitutes a capital loss or a loss deductible from ordinary income as cost of goods sold, as an ordinary and necessary business expense, or as a business loss; and (2)...
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