OPINION
GOFFE, Judge:
The Commissioner determined a deficiency of $429,327 in the Federal corporation income tax of petitioner for the taxable year ended October 31, 1972. This matter is before this Court on a joint motion for partial summary judgment pursuant to Rule 121 of the Court's Rules of Practice and Procedure. The motion raises one issue for decision, whether the net operating loss of Homecraft Products, Inc. (a wholly owned subsidiary of...
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