Memorandum Findings of Fact and Opinion
SACKS, Commissioner:
Respondent determined a deficiency in petitioners' Federal income tax for the year 1967 in the amount of $411.25. Three issues are presented for our decision: (1) Whether petitioners may deduct a claimed loss of $2,645 arising from the sale of their former residence located in Boise, Idaho in 1967, under the provisions of section 165(c)(2), Internal Revenue Code of 1954;
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