FORRESTER, Judge:
Respondent has determined a deficiency in petitioners' 1951 income tax in the amount of $12,861.64. The sole issue remaining is whether he erred in characterizing a payment by petitioners in the amount of $31,150 as a long-term capital loss.
FINDINGS OF FACT.
The stipulated facts are so found.
Petitioners are husband and wife residing in Brooklyn, New York. Their joint income tax return for 1951 was filed March 7...
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