DRENNEN, Judge:
Respondent determined a deficiency in petitioner's Federal income tax liability in the amount of $51,228.38 for the tax year ended June 29, 1985. The sole issue for our decision is whether petitioner is entitled to deduct a loss of $111,366 on the resale of a terminated executive's house in the tax year ended June 29, 1985. Resolution of this issue is primarily dependent upon whether petitioner held the house other than as a capital asset inasmuch...
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