Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined a deficiency in income tax for the year 1953 in the amount of $2,671.13. The question is whether the petitioner sustained a loss in 1953 under section 23(c) (2) in the amount of $3,965.95 when he made payments in that year to 2 persons to compensate them for losses from sales of stocks in earlier years which they had purchased with their own funds; or whether the petitioner...
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