Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in income tax for the calendar years 1959, 1960, and 1961 in the respective amounts of $4,353.80, $3,280.02, and $2,770.04, and an addition to tax under section 6651(a) of the Internal Revenue Code of 1954 for delinquency in filing the return for 1959 in the amount of $1,080.92.
The issues for decision are (1) what was the amount of the loss sustained by the...
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