Memorandum Findings of Fact and Opinion
This proceeding involves income tax deficiencies of $561 for 1944 and $260 for 1945. The deficiencies for both years result from the respondent's determination that losses on real estate sales, which the petitioner deducted in full in his income tax returns as ordinary losses, were capital losses subject to the limitations provided for in section 117, Internal Revenue Code.
Findings of Fact
The petitioner...
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