Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1956, 1958, 1959, and 1960 in the amounts of $19,030.53, $123,983.46, $499,066.30, and $463,389.89, respectively.
Some of the issues raised by the pleadings have been disposed of by agreement of the parties leaving for our decision the following:
1. With respect to the year 1956:
A. Whether losses...
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