Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined a deficiency in petitioner's federal income tax for the taxable year 1967 in the amount of $1,571.16. The issue in controversy is the proper calculation of the gain or loss arising from a foreclosure sale of an apartment house in which petitioner had a one-half interest. Petitioner also claims that he has a net operating loss carryover available for the year in issue.
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