MEMORANDUM OPINION
MEHRTENS, District Judge.
This is a civil action for the refund of federal income taxes and interest thereon in the amount of $1,564.84 paid to the defendant by the plaintiff for the years 1961 and 1962.
The only issue to be decided is whether plaintiff, Harry C. Caplan, is entitled to deduct his partnership share of a loss on the sale of a building to a corporation owned by his brother, by offsetting the loss against installment...
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