Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency of $1,334.19 for the year 1952 in the case of Abel Louis Lajtha, and deficiencies of $170.90 and $1,381.08 for 1953 and 1954, respectively, in the case of both petitioners. The sole contested issue concerns a loss claimed for 1952 giving rise to a net operating loss carry-over for the following years. The petitioners claim an overpayment of $652.40 for 1953. The...
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