Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax for 1947 in the amount of $10,809.11. The only issue for decision is whether $18,000 should be deducted in computing a net loss of the petitioner for 1949 as the basis for a net operating loss deduction for 1947 under section 23(s) and section 122.
Findings of Fact
The petitioner was incorporated in 1932 under the laws of Rhode Island, and has at all...
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