Memorandum Findings of Fact and Opinion
This proceeding involves an income and victory tax deficiency of $5,200.42 for 1943. The petitioner reported in his 1942 return a loss from the sale of property. He deducted that loss and thereby showed a net loss for 1942 which he carried over and deducted in his 1943 return. The Commissioner disallowed the amounts deducted in both years under section 24(b) of the Internal Revenue Code. The sole question is whether the petitioner...
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