Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies in petitioner's 1971 and 1974 Federal corporate income tax of $22,167 and $1,576, respectively. The sole issue for decision is whether petitioner realized an ordinary or capital loss upon the sale of 45,000 shares of Banner Industries, Inc. stock in 1974.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
Petitioner...
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