Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the taxable year ended June 27, 1959, in the amount of $113,628.03.
The issue for decision is whether petitioner, in computing its net operating loss deduction for its fiscal year 1959, is entitled to a carryback from its fiscal year 1962, determined with a deduction in the later year as ordinary and necessary business expenses...
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