Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1957 and 1960 in the amounts of $2,304.16 and $2,229.23, respectively. The deficiency for the year 1957 resulted from the disallowance of a net operating loss carryback to the year 1957 from the year 1960 which carryback had been previously tentatively allowed.
The issue for decision is whether petitioners are entitled...
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