This proceeding involves deficiencies in income tax in the amounts of $2,134.70 and $1,046.87 and in declared value excess profits tax in the amounts of $883.73 and $172.28 for 1944 and 1945, respectively. The issues are whether respondent erred in capitalizing each year, subject to depreciation, certain amounts claimed in returns as ordinary and necessary business expenses, and not allowing, as a deduction in 1944, a net operating loss of not less than $2,765.59 during 1946...
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