Respondent has determined a deficiency in petitioner's income tax for the calendar year 1954 in the amount of $6,000.10. The issue remaining for decision is whether a loss sustained by petitioner may be deducted as a business loss under section 165 of the Internal Revenue Code of 1954.
FINDINGS OF FACT
The stipulated facts are hereby found accordingly.
Petitioners, Valentine Howell (hereinafter referred to as petitioner) and his wife, Loretta B....
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