MEMORANDUM FINDINGS OF FACT AND OPINION
ARMEN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1992 in the amount of $4,339.
The issue for decision is whether a certain loss, which respondent concedes is deductible, was incurred in 1992 as petitioners...
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