ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1963 in the amount of $246,089.75. Certain issues having been disposed of by agreement of the parties, the only issue remaining for decision is whether short-term capital losses in the amount of $967,760.60 resulting from short sales of securities in the stock market are properly deductible for the taxable year 1963.
FINDINGS OF FACT
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