Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax for 1954 in the amount of $1,046.46, and made an addition to the tax of $739.07 for a substantial underestimation of estimated tax under section 294(d)(2), 1939 Code. The questions for decision are as follows: (1) Whether petitioner sustained an ordinary loss in a transaction entered into for profit under section 165(c)(2), 1954 Code, upon the termination of his employment...
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