Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for 1976 in the total amount of $57,829. After concessions, the issues for decision herein are as follows:
(1) Whether petitioners' loss upon the sale of 10,000 shares of common stock of Texfi Industries, Inc. is deductible as an ordinary loss or a capital loss under section 165;
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