SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1959 and 1960 in the amounts of $3,745.64 and $1,433.40, respectively.
The issues for decision are:
(1) Whether for the calendar year 1959 petitioner is entitled to a loss carryover in excess of the amount allowed by respondent.
(2) Whether, to the extent of $2,387.51, the deficiency in income tax determined by respondent for the year 1959...
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