Memorandum Opinion
NAMEROFF, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180 et seq.
Respondent determined a deficiency in petitioner's 1985 Federal income tax in the amount of $3,958. The sole issue for consideration is whether petitioner is the owner, for tax purposes, of certain real estate in Loveland, Colorado, and is therefore entitled to deduct a loss incurred...
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