Memorandum Opinion
DAWSON, Judge:
Respondent determined a deficiency of $15,280 in petitioner's Federal income tax for the year 1970.
The primary issue remaining for decision is whether the petitioner realized long-term capital losses on the sales of its interests in two tuna fishing vessels or ordinary losses on the sales of property used in its trade or business. The resolution of this issue depends upon whether the petitioner's ownership interests...
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