Memorandum Findings of Fact and Opinion
FAY, Judge:
The respondent determined a deficiency in the petitioners' income tax for the calendar year 1955 in the amount of $5,005.94. The only issue for decision is whether, in computing the petitioners' net operating loss deduction allowable as a carryback to 1955, the loss sustained by petitioners on the sale of their former residence in 1958 constituted a loss on property used in petitioners' trade or business...
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