Memorandum Findings of Fact and Opinion
In this proceeding respondent has determined a deficiency in petitioner's income tax liability for the year 1936 in the sum of $1,643.32. Petitioners alleged that they have overpaid their tax for that year by the amount of $1,561.26. The issue presented herein is whether petitioner, Augustus S. Loyless, realized a taxable gain (and if so the amount thereof) or sustained a loss upon the liquidation of the Loyless Publishing...
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