OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $807.92 in income tax of the petitioners for 1949. The only issue for decision is whether a partner's share of Internal Revenue Code, 1939, section 117 (j), loss of the partnership is to be offset by individual section 117 (j) gains of the taxpayer-partner. The stipulation of the parties is adopted as the findings of fact.
The petitioners, husband and wife, filed a joint...
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