Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $109,690.00 in the petitioners' 1969 Federal income tax. The parties have settled some of the issues. The issue remaining for decision is whether the petitioners are entitled to carryover a long-term capital loss to 1969 resulting from the worthlessness of certain stock. Resolution of such issue depends on (1) whether the petitioners have carried their burden...
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