Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the years ended December 31, 1971 and December 31, 1972, in the respective amounts of $24,175.63 and $15,926.67.
The issue for decision is whether petitioner is entitled to deduct as a loss under section 165, I.R.C. 1954,
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