Memorandum Findings of Fact and Opinion
ATKINS, Judge:
Respondent determined deficiencies in income tax in the amounts of $1,103.01, $1,107.93, $863.21 and $181.00 for the taxable years 1961, 1962, 1963, and 1964, respectively. The only issue for decision relates to the treatment to be accorded the loss of $39,000 sustained by petitioners upon the termination of their wholly owned corporation in 1964. The only issue relating to the taxable years 1961, 1962...
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