Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies of income tax of $86,307.70 for 1946, $3,032.01 for 1947 and $2,638.46 for 1948. The only issue for decision is whether the petitioner sustained a net operating loss in any amount during 1946. That depends upon the basis, in this case cost, of 57.798 acres of land sold in 1946. The excess loss, if any, would carry over to the two later years.
Findings of Fact
The petitioner...
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