Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioners' income taxes for the taxable year 1964 in the sum of $4,384.29. This deficiency arises from the partial disallowance by respondent of a net operating loss claimed for the year 1960. The sole issue for decision is whether petitioners are entitled to a deduction in 1960 under either sections 165 or 166
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