Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent has disallowed a deduction in 1946 of $25,000 which the petitioner claims represents the amount of a casualty loss. The deduction is claimed under section 23(e)(3) of the Internal Revenue Code. The respondent's determination gives rise to a deficiency in income tax for 1946 in the amount of $14,471.64.
The question to be decided is the amount of the casualty loss to residential...
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