Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $271.96 in petitioners' income tax for the taxable year 1962.
Petitioners have failed to urge consideration of certain issues raised in the pleadings. We therefore find that they have abandoned them. The sole issue left for decision is whether petitioners are entitled to a deduction for a loss arising from a "trade or business" as that term is used in the Internal...
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