Memorandum Findings of Fact and Opinion
PIERCE, Judge:
Respondent determined deficiencies in the income taxes of the petitioners for their taxable calendar years 1959 and 1960, in the amounts of $980.76 and $2,940.67, respectively.
The issues for decision are:
(1) Whether petitioner Frank DeGoff is entitled to a deduction of $60,000 for the year 1960, for an alleged embezzlement loss.
(2) Whether certain payments received by said...
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