Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in the joint Federal income tax returns of petitioners for the taxable years 1968 and 1969 in the amounts of $10,443.11 and $5,376.01, respectively. Due to concessions by the parties the issues for our decision are as follows:
(1) Whether petitioners abandoned their franchise in the taxable year 1968 thereby sustaining a loss.
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