Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency of $4,320 in petitioners' income tax for the calendar year 1968. At issue is whether a loss sustained in 1968 upon the sale of certain real property must be treated as a capital loss subject to the limitations of section 1211(b), I.R.C. 1954.
Findings of Fact
The parties have filed a stipulation of facts along with exhibits which is incorporated...
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