Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
In these consolidated cases the Commissioner determined deficiencies in the joint income tax liability of petitioners H. Earl Smalley, Jr., and Eleanore H. Smalley in the amount of $71,457.59 for 1960 and $2,048.14 for 1961, and issued separate statutory notices. Petitioners conceded the 1961 deficiency. We are asked to determine:
(1) The amounts of the net operating losses of two subchapter...
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