Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined deficiencies in petitioners' income tax for the taxable years 1964 and 1965 in the respective amounts of $3,857.28 and $7,558.99.
The issues for our consideration are: (1) Whether the loss sustained by petitioner in 1964 due to the worthlessness of his common stock in Bohemian Surf Equipment Manufacturing Company is deductible by him as a business...
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