United States Tax Court.
Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency in the petitioner's income tax for 1951 in the amount of $213,581.38. The issue before us is whether petitioner is entitled to a net operating loss carry-back from 1952, because of a claimed loss of $443,000 in such year, either under section 23(k) of the Internal Revenue Code of 1939, which amount represents...
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