Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in income tax in the amount of $77,199.49 against petitioner for the year 1949. The sole issue presented for decision is whether a loss with respect to certain Florida real estate occurred in 1949. A stipulation of facts filed by the parties and certain facts stipulated orally by the parties at the hearing are incorporated herein by reference as part of our findings...
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