Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined a deficiency in income tax for 1962 in the amount of $173. The only issue is whether an alleged capital loss deduction is allowable for 1962, limited to $1,000 under section 1211(b), 1954 Code, as a capital loss carryover from 1960. The questions are whether a capital loss was sustained in 1960 and whether the amount was $3,000.
Findings of Fact
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