STERRETT, Judge:
In his notice of deficiency dated August 28, 1979, respondent determined a $78,440.97 deficiency in petitioners' Federal income tax for the year 1973. In an amendment to his answer, respondent asserted an additional deficiency in the amount of $13,249.03. After concessions by the parties, the primary issues remaining for decision are:
(1) Whether petitioner Leroy Frantz, Jr., sustained a loss during 1973 from surrender to a corporation...
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