Memorandum Findings of Fact and Opinion
SACKS, Commissioner:
Respondent determined deficiencies in petitioners' Federal income tax for the years 1966 and 1967 in the respective amounts of $250 and $31.25. The sole issue for decision is whether the purchase by petitioners of shares of the capital stock of the Palo Alto Hills Golf and Country Club, a California Corporation, in 1958, was a transaction entered into for profit, so that the loss sustained by them...
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