Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in petitioner's 1970 and 1971 income taxes in the amounts of $1,356.54 and $1,308.54, respectively. At issue is the availability of deductions based upon carryovers of an alleged $325,000 Cuban confiscation loss which petitioner claims occurred after he became a resident alien of this country in October, 1960. A stipulation of facts filed by the parties is incorporated...
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