The Commissioner determined a deficiency of $7,602.78 in the income tax of the petitioners for 1951. The issues for decision are whether the Commissioner understated the petitioners' net operating loss for 1952 for the purpose of the 1951 net operating loss deduction by regarding as nonoperating losses a loss of $15,776.13 on the sale of breeding-herd cattle and a loss of $598.96 from the sale of a combine.
FINDINGS OF FACT.
The petitioners are husband and...
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