Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioner's income tax for the calendar years 1952 and 1954 in the respective amounts of $266,717.65 and $236,233.67. The year 1952 is in issue only because petitioner claims a loss for 1954 which it seeks to carry back to 1952.
The issues remaining for our determination are (1) whether petitioner suffered a loss of $1,634,544.45 in 1954 because of...
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