OPINION
BRUCE, Judge:
Respondent determined a deficiency in the income tax of petitioner for the taxable year 1958 in the amount of $1,735.65. The sole issue is whether petitioner is entitled to a deduction as a long-term capital loss in the amount of $12,918.87 resulting from its transfer of securities to the fiduciary of its profit-sharing trust in payment of its contribution thereto.
All of the facts are stipulated and are found accordingly...
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