Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency of $27,109.19 for the taxable year ended December 31, 1954.
The only issue for decision is whether the Commissioner properly disallowed $149,300 which was claimed as a carryover of a capital loss resulting from the sale of the cigar brand name "Henrietta" in the year 1952.
Findings of Fact
Some of the facts are stipulated, are so found...
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