Respondent determined a deficiency of $64,681.27 in petitioner's income tax for the calendar year 1952. Petitioner has paid $5,531.39 of this amount, so that the net deficiency involved herein is $59,149.88.
The deficiency arises by reason of respondent's determination that losses of $113,781.01, which petitioner sustained during the taxable year in closing out contracts for the future delivery of English
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