Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1966 and 1967 in the amounts of $2,446.18 and $1,139.45, respectively. The deficiencies resulted from disallowance of an ordinary loss claimed by petitioners on their 1969 income tax return which was carried back to 1966 and 1967. The loss in controversy denied on petitioners' 1969 return was a loss in the amount of $23,750...
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