HALL, Judge:
Respondent determined a $139,114.17 deficiency in petitioner's Federal income tax for its taxable year ended June 30, 1970. The three issues presented are:
(1) Whether the 3600 shares of capital stock of Nor-West Fabrics, Inc., owned by petitioner were capital assets in petitioner's hands when the stock became worthless during petitioner's taxable year ended June 30, 1970.
(2) Whether petitioner's loans to Nor-West Fabrics, Inc...
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