Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the years 1967, 1968, 1969, 1970 and 1971 in the respective amounts of $1,055, $5,482.55, $10,535, $3,748.47 and $6,038.72.
The issues for decision are:
(1) Whether petitioners are entitled under section 165 (c) (3), I.R.C. 1954,
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