MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Year Deficiency 1998 $ 801 1999 32,509
The issue for decision is whether petitioners are entitled to claimed capital loss carryover deductions relating to a 1995 purported sale of residential property located in Honolulu, Hawaii.
Unless...
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