Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
This case involves an income tax deficiency of $1,543.14 determined by the respondent for the year 1939. The question presented is whether respondent erred in disallowing a deduction of $54,342.94 claimed by petitioners as a loss, under section 23(e), Internal Revenue Code, or as an expense, under section 23(a), Internal Revenue Code. The case was submitted on original and supplemental stipulations of...
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