Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
In these consolidated proceedings respondent determined the following deficiencies in income tax for the calendar year 1945:
Roman S. Gontarek .......... $6,833.21 John J. Gontarek ........... $7,108.27
The issues fall into three categories.
First: Was the loss incurred by petitioners upon the sale in...
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