OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $661.33 in income tax of Bessie E. Machris for 1954. The facts have been submitted by a stipulation which is adopted as the findings of fact. The only issue for decision is whether $1,537.98 paid by Bessie in 1954 was deductible under section 212 as nonbusiness expenses rather than deductible as a long-term capital loss.
Bessie filed an individual income tax return for 1954...
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