Memorandum Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1951, 1952, and 1953 in the amounts of $1,857.04, $257.47, and $1,555.98, respectively. The only issue raised by the pleadings is whether petitioners are entitled to deduct a loss on the involuntary conversion of an interest in rental property owned by petitioner Chester N. Williams as an operating loss in the year 1951, and carryovers of that loss...
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