OPINION
EKMAN, Judge:
Respondent determined deficiencies in petitioner's income taxes for the calendar years 1974 and 1975 in the amounts of $41,639.14 and $6,269.73, respectively, and an addition to tax under section 6653(a), I.R.C. 1954, for 1974 in the amount of $2,081.95.
Due to concessions by the parties, the issues remaining for decision are (1) whether consolidated net operating losses which were incurred...
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