Memorandum Findings of Fact and Opinion
WITHEY, Judge:
A deficiency has been determined by the Commissioner in the income tax of petitioners for the taxable year 1963 in the amount of $22,936.78.
The sole issue to be decided is whether respondent has erred in disallowing a loss deduction taken by petitioners in their income tax return for 1963 under section 165 of the Internal Revenue Code of 1954.
Findings of Fact
All of the stipulated...
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