Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined an income tax deficiency of $864.12 for 1953. With respect to different pieces of real estate located in Budapest, Hungary, each petitioner claims a net operating loss in 1952 with carryovers to 1953. The questions are whether each property was taken in 1952 by the Hungarian Government, and whether each taxpayer was engaged in a trade or business with respect to each property...
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