Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax in the years 1955 and 1957 in the amounts of $4,973.12 and $132.63, respectively. The only issue for decision is whether the closing of the books of the partnership known as Penn Clif Company in 1955 resulted in petitioner E. Comer Smith incurring a deductible loss in the amount of the final balance in his partnership capital account.
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