Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax for the calendar year 1976 in the amount of $8,562.48. The issues for decision are whether petitioners sustained a loss in 1976 as a result of certain transfers to Towne Kar Kare, Inc., and if so, whether it is capital or ordinary.
Findings of Fact
Some of the facts have been stipulated and are so found.
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