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PETERSEN v. COMMISSIONER

Docket No. 4525-67.

30 T.C.M. 95 (1971)

T.C. Memo. 1971-21

Morton Q. Petersen v. Commissioner.

United States Tax Court.

Filed January 25, 1971.

Attorney(s) appearing for the Case

George R. Blue and A. J. Schmitt, Jr., Suite 300, The Howard Triangle, 833 Howard Ave., New Orleans, La., for the petitioner. Bruce A. McArdle, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $23,943.27 in petitioner's income taxes for 1959.

The central issue for decision is the extent to which petitioner incurred a net operating loss in 1961 which, pursuant to section 172,1 can be carried back and offset against his income for an earlier year.

Findings of Fact

All of the facts have been stipulated...

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