Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies in the income tax of petitioners for the years 1950 and 1951 in the respective amounts of $1,272.58 and $123.98.
The questions in the case are:
(1) Are petitioners entitled to a business loss deduction in the amount of $6,964 under section 23(e)(1) of the Internal Revenue Code of 1939 for the taxable year 1950 as the result of a sale of real estate...
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