Memorandum Findings of Fact and Opinion
HOYT, Judge:
The Commissioner determined a deficiency in petitioner's income tax for the year 1958 in the amount of $2,351.96 and an addition to the tax for negligence pursuant to section 6653(a) of the Internal Revenue Code of 1954, in the amount of $117.60. The sole issue for decision is whether petitioner is entitled to a net operating loss deduction in the amount of $135,356.06, representing carryover losses of...
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