Memorandum Opinion
BLACK, Judge:
The respondent has determined a deficiency in income tax for the year 1951 in the amount of $601.44. The sole issue is whether the petitioners are entitled to a net operating loss carryback from the year 1952 in the amount of $135.59, as determined by the respondent, or in the amount of $3,172.37, as reported by the petitioners.
All of the facts have been stipulated and are found accordingly.
[Findings...
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