Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency of $44,922 in the petitioners' income tax for the year 1953. This was based upon the disallowance of a claimed net operating loss carryover deduction and an increase in the reported capital gain upon the sale of certain property. A number of issues were raised by the petition, but all of them were abandoned either at the hearing or on brief, except the issue as...
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