MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge.
Respondent determined a Federal income tax deficiency for petitioner's tax year ended December 31, 1995, in the amount of $37,537. Respondent also determined an addition to tax for said year of $5,631, pursuant to section 6651(a)(1).
The issues for decision are:
(1) Whether petitioner sustained an abandonment loss during tax year ended 1995 that qualifies as a deductible loss pursuant to...
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