Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $205 in the income tax of the petitioners for 1952. The only issue for determination is the correctness of the respondent's disallowance of a deduction of $22,097.72 taken by petitioners as a loss sustained by petitioner Abraham J. Gordon in the conduct of a sole proprietorship business.
Findings of Fact
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