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Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513 (10th
Cir. 1947).
In view of the foregoing, we hold that petitioner is not
entitled to a loss deduction under section 165 in any amount
greater than that conceded by respondent.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disposition of the disputed issue, as well as
respondent’s concessions,
Decision will be entered for
respondent as to the overpayment in
income tax for 1989 and for
petitioner as to the deficiencies
in income taxes and penalties under
section 6663.
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Last modified: May 25, 2011