Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined deficiencies in the federal income taxes of petitioners William N. Gurtman and Ida Gurtman and petitioners Aaron Schomer and Violet Schomer for the taxable year 1967 in the amounts of $8,231.15 and $3,144, respectively. The sole issue for decision is whether an ordinary loss deduction is allowable under section 165(a) and (c), I.R.C. 1954,
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