Petitioner seeks redetermination of deficiencies in income tax for 1946 and 1947 of $679.66 and $61, respectively, and claims overpayment of income tax for 1946 in the amount of $7,032.23. The controversy involves wagering losses which exceed wagering gains, and the issues are whether a net annual wagering loss may offset income of the same year from other sources and whether it may be taken into account in computing net operating loss carry-overs and carry-backs.
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