TIETJENS, Judge:
Respondent determined deficiencies in the income taxes of petitioners for the taxable years 1961 and 1962 in the amounts of $3,267.42 and $3,550.69.
Some adjustments made by respondent have either been conceded or abandoned by petitioners, thus leaving three issues for our decision:
(1) Does section 267(a)(1), I.R.C. 1954, prohibit the deduction of a capital loss, and resulting capital loss carryovers, where the Internal Revenue...
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