Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax against the petitioner for the calendar year 1935 in the sum of $3,599.51. The first issue is whether a loss sustained by the petitioner, as one of the owners of mortgaged property, upon the voluntary conveyance of that property by those owners to the mortgagee in lieu of foreclosure was an ordinary loss deductible in full, or a capital loss, deductible only to the limited...
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