Memorandum Findings of Fact and Opinion
RUWE, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for taxable years 1986 and 1987 in the amounts of $3,870 and $21,621, respectively.
After concessions, the sole issue for decision is whether petitioners may deduct losses and the attendant carryovers from the expropriation of petitioners' property by the Iranian Government which they claim occurred during the years 1983, 1986...
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