Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1959, 1960, and 1961 in the amounts of $179.99, $206, and $168.51, respectively.
The issues for decision are:
(1) Whether the loss sustained by petitioners in 1958 upon the sale of a house, formerly their residence, which had been rented for approximately 14 months prior to the date of sale, is a capital...
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