Memoradum Opinion
SMITH, Judge:
This proceeding involves a deficiency of $3,380.43 in petitioner's income tax for 1941. The only issue is whether petitoner is entitled to the deduction in his individual income tax return for 1941 of an operating loss from rental properties which during that year were held by a wholly owned corporation. There is no dispute as to the facts.
[The Facts]
Petitioner is a practicing attorney with offices...
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