AUGUSTUS N. HAND, Circuit Judge.
This petition for review involves a deficiency of $36,584.54 in the income taxes of Arnold Constable Corporation, a Delaware company. The taxes in controversy are for the fiscal year of that company from February 1, 1927, to January 31, 1928. The deficiency resulted from the holding of the Commissioner that no part of the loss suffered in the fiscal year ended January 31, 1926, by petitioner's affiliate Arnold Constable & Co.,...
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