Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income taxes for the years 1975 and 1976 in the amounts of $870.63 and $161, respectively, and additions to tax for negligence under section 6653(a), I.R.C. 1954, in the amounts of $43.53 and $8.05, respectively.
Due to concessions by the parties, the only issues remaining for decision are (1) whether petitioners are entitled to deduct "loss...
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