MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for 1986 and 1988 in the respective amounts of $6,551 and $3,043, and additions to tax for 1986 and 1988 under section 6651(a)(1) in the respective amounts of $1,471 and $357.
Following a concession by petitioner, the issues for decision are: (1) Whether petitioner is entitled to deduct $47,405 as a business foreclosure loss...
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