MEMORANDUM OPINION
JACOBS, Judge:
Respondent determined a $22,476 deficiency in petitioners' 1989 Federal income tax and a $4,495 accuracy-related penalty under section 6662(a).
Following concessions by respondent, two issues remain for decision from respondent's notice of deficiency: (1) Whether petitioners properly claimed a $60,000 capital loss as a result of petitioner Santar Yei's surrender of 60,000 shares of stock in Cirtex, Inc. (Cirtex)...
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