Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined a deficiency of $3,570.68 in the petitioner's income tax for the fiscal year ended April 30, 1949. The only issue presented by the pleadings is whether the respondent erred in failing to allow $8,390.77 as a deduction for the taxable year in question as a net operating loss carry-back from the fiscal year ended April 30, 1950.
Findings of Fact
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