Memorandum Opinion
STERNHAGEN, Judge:
An income tax deficiency for 1940 of $824.01 was determined as the result of the disallowance of a deduction of $2,497 taken by the taxpayer as a capital loss from the sale for $6 of 100 shares of Plant Cultivation Co., the Commissioner holding that "the stock had become worthless in a prior year."
[The Facts]
The taxpayer's 1940 return was filed in the Second District of New York. In 1935, he...
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