WITHEY, Judge:
Deficiencies have been determined in the income tax of petitioners for the calendar years 1954 and 1955 in the respective amounts of $11,224.42 and $1,060.26 and additions to tax under sections 294(d) (1) (B) and 294(d) (2) of the Internal Revenue Code of 1939 for 1954 in the respective amounts of $67.50 and $253.47.
The issues for decision are (1) whether respondent has erred in treating as a capital loss a loss deduction taken by petitioners...
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