Memorandum Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for 1976 as follows:
Docket Number Deficiency 13845-79 .................. $28,170.94 13847-79 .................. 25,097.38
The sole issue for decision is whether petitioners sustained an ordinary loss or a capital loss upon the voluntary reconveyance...
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