Memorandum Opinion
LEECH, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1938 in the amount of $607.52. In his income tax return for that year, filed with the collector of internal revenue for the Second District of New York, the petitioner deducted $3,036.75, which was 50 per cent of an alleged loss of $6,073.50, based upon a sale by petitioner in the taxable year of 4.74 shares of common stock of the Middle West...
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