Memorandum Opinion
SMITH, Judge:
This proceeding involves income tax deficiencies of $2,260.30 for 1940 and $1,680.23 for 1941. Petitioner alleges in his petition that the respondent erred in disallowing the deduction in each of those years of a portion of a net loss sustained in 1939. At the hearing, however, a written stipulation of facts was submitted in which petitioner conceded the correctness of the respondent's determination as to the year 1941.<...
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