MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a deficiency in petitioners' Federal income tax of $19,675 and an accuracy-related penalty under section 6662 of $3,935 for 1995.
The issues for decision are:
1. Whether petitioners may deduct an ordinary loss of $100,000 under section 1244 for loss in value of petitioner's FabuGlass stock in 1995. We hold that they may not.
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