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fiduciary within the meaning of section 267(b)(4). Such being
the case, we hold that the claimed loss is not allowable under
section 267(a), which we note covers losses not only "directly"
but also "indirectly" from the proscribed sales or exchanges.
Supra p. 5.
In accordance with the foregoing,
Decision will be entered for
respondent for the amount of the
increased deficiency, and decision
will be entered for petitioners as
to the accuracy-related penalty.
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Last modified: May 25, 2011