Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax for the calendar year 1946 in the amount of $3,712.65. In his petition, the petitioner claims an overpayment in income tax for 1946. The issues to be decided are (1) whether petitioner is entitled to a deduction during 1946 for a loss from the abandonment of his 50 per cent interest in a patent; (2) if petitioner is entitled to such deduction, what amounts expended in the...
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