Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By letter dated November 25, 1977, respondent determined a deficiency in income tax due from petitioners in the amount of $11,254.02 for their taxable year ended December 31, 1974. The issues for our determination are: (1) whether petitioners suffered a loss due to the worthlessness of notes or stock, (2) if stock, whether the stock was section 1244 stock, and (3) the year of worthlessness. While respondent...
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