Memorandum Opinion
DAWSON, Judge:
Respondent determined an income tax deficiency against petitioner for the year 1963 in the amount of $428.23. The only issue presented for decision is whether the petitioner is entitled to a capital loss deduction under the provisions of section 165(c)(2), Internal Revnue Code of 1954, subject to the limitations of section 1211(b), resulting from the sale of Florida winter residence property held by her and her husband as...
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