OPINION
FAY, Judge:
Respondent determined the following deficiencies in the petitioners' income tax for the taxable years 1960 and 1963:
Year Deficiency 1960 ------------------------ $1,641.16 1963 ------------------------ 3,723.70
On their Federal income tax return for the year 1963, petitioners deducted $25,000 as an ordinary business loss...
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