Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding was brought to redetermine a deficiency in the income tax of the petitioners for the calendar year 1936 in the sum of $36,907.07. The determination resulted from the disallowance of the deduction of the sum of $74,700 as a loss on stock alleged to have become worthless in that year.
The only issue is whether the shares of the common stock of the Atlantic-Pacific Gas and Oil Company...
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