Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined deficiencies in petitioner's 1975 and 1978 Federal income tax in the amounts of $4,287 and $17,535, respectively. After concessions, the sole issue remaining is whether the stock of Billing's Block, Inc. ("BBI"), became worthless during 1981 entitling petitioner to a $5,000 capital loss carryback to 1978.
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