Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1952 in the amount of $12,379.45 together with an addition to tax under section 294(d)(2) of the 1939 Code in the amount of $419.64.
The issues for decision are:
(1) Whether the petitioner sustained a loss in the amount of $18,440.95;
(2) Whether the petitioner incurred an ordinary and necessary...
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