PIERCE, Judge:
The respondent determined a deficiency of $4,933.32 in the income tax of the petitioners for their taxable calendar year 1961.
The issues for decision are:
(1) Whether the petitioners are entitled to deduct an alleged loss of $41,075.56 on the sale in the taxable year by petitioner Ruthie N. Melone to persons named Learner, of residential property which had until May of the preceding year been occupied by said petitioner as her...
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