Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1960 and 1961 in the respective amounts of $1,699.42 and $4,610.25. The principal issue for decision is whether the petitioner is entitled in 1961 to a deduction in the amount of $97,484.15, claimed as a loss under section 165 of the Internal Revenue Code, on account of the collapse of a part of the roof of a building it owned...
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