OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1964 and 1965 in the amounts of $10,386.31 and $74,076.11, respectively.
The issue for decision is whether petitioner is entitled to carry back net operating losses and investment credits which arose after the merger into petitioner of its wholly owned subsidiary to eliminate income taxes of that subsidiary for years prior to the merger...
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