Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes of $280.72 and $10,701.61 for the years 1969 and 1970, respectively.
Concessions having been made, it remains for us to decide: (1) Whether construction by petitioners of certain residential property was an activity engaged in for profit so as to entitle them to a deduction for a loss incurred on the sale of the property; and...
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