STERRETT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1968 in the amount of $143,895.95. Due to concessions made by the parties, four issues remain for our determination: (1) Is shareholder petitioner entitled to a deduction for a portion of the net operating losses of the two subchapter S corporations as calculated at their year ended January 31, 1967, to the extent of his stock basis and basis of indebtedness...
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