Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined a deficiency in petitioner's federal income tax for the calendar year 1973 in the amount of $2,217.07. The principal issue for decision is whether petitioner, Joseph M. Kaspar, is entitled, on his 1973 return, to an ordinary loss or capital loss deduction for the sale, at a loss, in 1973 of foreign patent rights to an unrelated party.
Finding of Facts
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