Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1973 in the amount of $1,750.22.
The issues for decision are (1) whether petitioners are entitled to a deduction of a net operating loss carryover to the taxable year 1973, and if so, the amount of such carryover; and (2) whether respondent was barred from determining a deficiency for the year 1973 by petitioners...
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