Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in the income tax liability of petitioner for the taxable years 1967 and 1968 in the respective amounts of $1,600.60 and $10,279.30. These deficiencies result from numerous adjustments made by respondent.
There is only one adjustment at issue in the present case and that is whether petitioner is entitled under section 165
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