Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent has determined deficiencies in income tax against the petitioner for 1940 and 1941 in the respective amounts of $32,611.82 and $20,426.50. The issues presented are the correctness of the respondent's disallowance of (1) a deduction of $372,056.42 taken by petitioner in 1940 as a long-term capital loss sustained on shares of preferred stock owned by it in Victor Lynn Transportation Company...
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