OPINION.
DRENNEN, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1953 in the amount of $2,813.30.
The sole issue is whether, in computing the net operating loss deduction for 1953, a net operating loss carryback from the calendar year 1955 to the calendar year 1953 must be reduced by 50 per cent of the long-term capital gains realized in 1953. This in turn depends on whether the Internal Revenue...
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