Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined deficiencies in the petitioner's income tax of $788.61 for the taxable year 1961 and $39.40 for the taxable year 1962. The only issue for decision is whether the transaction in which the petitioner purchased his mother's home was a "transaction entered into for profit" so that his loss on the subsequent sale of the home is deductible under section 165 of the Internal Revenue...
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