The respondent determined a deficiency in income tax of $10,208.95 and a penalty of $1,020.90 under section 294 (d) (1) (A) of the Internal Revenue Code, for the year 1946. The penalty issue has been conceded by the respondent.
The issues for decision are (1) whether the petitioner sustained a deductible loss resulting from nationalization by the Czechoslovakian Government of the assets of a Czechoslovakian corporation of which the petitioner was the principal stockholder...
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