Memorandum Opinion
SMITH, Judge:
The petitioner assails a deficiency determination in her income tax for 1938 in the amount of $3,558.92. She alleges that the respondent erroneously disallowed the deduction of a capital loss in the sum of $13,412.25.
[The Facts]
The facts have been stipulated as follows:
1. That the taxpayer duly filed her 1938 income tax return with the Collector of Internal Revenue for the third District...
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