Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined a deficiency of $86,133.67 in petitioner's Federal income tax for its taxable year 1969.
The sole issue presented here for our decision is whether petitioner may carry back to its 1969 taxable year, in which it filed a separate return, a loss generated during the 1972 taxable year in which a consolidated return was filed. The loss in issue was primarily attributable to a...
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