The respondent determined a deficiency in the income tax of petitioner in the amount of $6,270.50 for the fiscal year ending June 30, 1948.
The issues are:
(1) Is the petitioner entitled to a net operating loss carry-back deduction in its taxable year ending June 30, 1948, of the portion of the consolidated net operating loss of an affiliated group of corporations, which was sustained by a subsidiary of petitioner during the year ending June 30, 1950?
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