Memorandum Findings of Fact and Opinion
HOYT, Judge:
The respondent determined deficiencies in the petitioners' income taxes for the calendar years 1961 and 1962 in the amounts of $698 and $694.45, respectively.
The issues remaining in the case for our decision are as follows:
(1) Whether the petitioners may deduct $2,287 in the year 1961 under section 165 of the 1954 Code as a loss incident to a forfeiture.
(2) Whether the petitioners...
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