RAUM, Judge:
On May 10, 1971, petitioners filed an application for refund of income tax for years prior to 1970 based on a carryback of a claimed 1970 net operating loss and an unused investment credit for that year. The Commissioner determined that petitioners were not entitled to refunds and that there were deficiencies in petitioners' income tax of $427,056.13 for 1968 and $66,440.13 for 1969. Additionally, the Commissioner...
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