Memorandum Opinion
QUEALY, Judge:
Respondent determined a deficiency of $95,873.10 in petitioner's income tax for the year 1967.
The principal issue presented for decision is whether the period January 1, 1968, to June 30, 1968, is the third "taxable year preceding" calendar year 1970, so as to prevent the carryback of petitioner's 1970 net operating losses to calendar year 1967 under section 172...
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