Respondent has determined a deficiency in petitioner's Federal income tax for the taxable year 1967 in the amount of $19,210.85. The issue for decision is whether petitioner, as successor by merger, is entitled to carry back a portion of its net operating loss to the 1967 premerger income of Romy Hammes, Inc., an Illinois corporation. The resolution of this issue depends largely on whether the multicorporate...
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