Memorandum Opinion
OPPER, Judge:
Respondent determined a deficiency in income tax of $31,432.25 against petitioner for 1947, all of which is in controversy. The single question is whether petitioner as the parent-affiliate of a consolidated-return group may carry-back a net loss of the group, not attributable to petitioner's operations, to a year prior to the consolidated return period. All of the facts are stipulated. They are hereby so found.
Petitioner...
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