Memorandum Opinion
TURNER, Judge:
The respondent determined deficiencies in income tax against the petitioner for the taxable years 1945 and 1946 in the respective amounts of $42,967.50 and $38,391.44. The only question remaining for decision is the amount of the net operating loss sustained by petitioner during the year 1947, which is available to him as a carry-back to the years 1945 and 1946, under section 122 of the Internal Revenue Code of 1939.
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