Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $48,450.85 in the taxpayer's income tax for the calendar year 1964 and a five percent addition to the tax under section 6653(a), I. R. C. 1954, in the amount of $2,422.54. The only issues remaining for decision are whether the taxpayer incurred a capital loss in 1964 resulting from the liquidation of Hageman Building and Development Company and whether he is liable for the addition...
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