Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined that there was a deficiency of $10,971.65 in the income tax of petitioners for 1980. The only issue is what part, if any, of a casualty loss of $22,482.74 is deductible by petitioners in 1980.
Findings of Fact
Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by reference.
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