OPINION.
TIETJENS, Judge:
The respondent determined deficiencies in income tax for the years 1946 and 1947 in amounts totaling $10,979.80. Several of the issues raised by the pleadings have been settled by stipulation and can be reflected in a Rule 50 computation.
The single issue for decision is the propriety of the respondent's failure, in determining the net operating loss carry-back to 1947, to...
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