Respondent determined an income tax deficiency against the petitioner for the year 1946 in the amount of $693.82, and in so doing denied to petitioner a net operating loss deduction claimed by petitioner under section 23 (s) of the Code. The net operating loss deduction for the year 1946, if petitioner is entitled to such deduction, arises out of a net operating loss sustained by petitioner during 1948.
The issue presented is whether petitioner sustained in 1948 a...
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