Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the fiscal years ended January 31, 1957, and January 31, 1959, in the amounts of $8,324.21 and $152,024.93, respectively. The deficiency for the year 1957 results from the disallowance of a claimed net operating loss carryback from the fiscal year 1959 to the fiscal year 1957, which claimed carryback loss had been tentatively allowed.<...
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