OPINION
TIETJENS, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $18,349.85 for 1971 and $2,164.44 for 1972. After certain concessions, the issue remaining is whether petitioner-husband, as beneficiary of the Estate of John C. Long, may use a net long-term capital loss carryover from the estate.
The facts have been fully stipulated. The stipulations of...
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