Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined income tax deficiencies against the petitioner for the years 1959 and 1962 in the amounts of $701,927.78 and $91,274.44, respectively.
Petitioner alleges in its petition a net operating loss for 1962, which may be carried back to 1959, greater than the amount determined by respondent and therefore claims that it is entitled...
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