The respondent has determined a deficiency of $142.26 in the petitioner's income tax liability for the taxable year ended December 31, 1945. This deficiency results from the disallowance in part of a deduction for intangible drilling costs. The petitioner does not assign this disallowance as error, but seeks a refund of income tax for the taxable year 1945, based upon a claim that he is entitled to a carry-over loss in that year resulting from a nonbusiness debt that became...
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