Memorandum Findings of Fact and Opinion
In its Corporation Income and Excess Profits Tax Return for the calendar year 1939, which was filed with the collector of internal revenue at Portland, Oregon, petitioner deducted the sum of $1,469,171.15 as representing losses due to the abandonment in that year of certain properties owned by the petitioner. Respondent has disallowed this deduction and has determined a deficiency of $112,437.05 in petitioner's income tax...
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