Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency in petitioners' Federal income tax for taxable year 1964 in the amount of $16,192.37.
The sole issue remaining for decision is whether petitioners' loss of $27,782.96 on their investment of $84,587.07 in Realty Transfer Corporation is an ordinary loss under section 1244.
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