Memorandum Findings of Fact and Opinion
SWIFT, Judge:
In a timely notice of deficiency, respondent determined a deficiency in petitioners, 1981 joint Federal income tax liability in the amount of $130,208. In his answer, respondent increased the amount of the deficiency to $171,834.
After settlement of some issues, the issues for decision are: (1) Whether petitioners are entitled to a small business stock loss under section 1244;
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