Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in petitioners' Federal income taxes as follows:
Year Amount 1968 ...... $6,380.94 1969 ...... 4,877.14 1970 ...... 5,924.19 1971 ...... 1,177.00
At issue is the character of a loss which petitioners sustained in 1971 upon the liquidation of Capell Associates...
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