United States Tax Court.
Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $3,702.86 with respect to petitioner's 1961 income tax. The issues for determination are:
(1) Whether respondent's disallowance of petitioner's claimed loss deduction was arbitrary and capricious in that respondent did not, prior to the issuance of the statutory notice of deficiency under section 6212...
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