MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
Respondent determined a deficiency in petitioners' 1990 Federal income tax in the amount of $43,446.
After concessions, the only issue for decision is whether a $65,316 loss claimed by petitioner Fred L. Baker (hereinafter petitioner) should be treated as an ordinary or capital loss.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts...
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