Memorandum Opinion
JOHNSON, Judge:
Respondent determined a deficiency in the income tax of Alexander Lincoln and Eleanor Ames Lincoln for the year 1949 in the amount of $3,705.30. The sole issue before us is whether they sustained a deductible loss when they surrendered certain capital stock pursuant to a plan of reorganization.
[Findings of Fact]
All of the facts were stipulated and are incorporated herein by this reference.
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