Memorandum Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in the petitioner's income taxes for the years 1966 and 1969 in the respective amounts of $6,288.51 and $4,078.07.
The only issue for decision is whether petitioner in 1969 incurred a loss on the sale or exchange of "section 1244 stock" which is entitled to treatment as an ordinary loss to the extent of $50,000.
All of the facts are stipulated and are found accordingly...
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