OPINION
SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for calendar year 1971 in the amount of $691,729.61. The issue for decision is whether petitioner is entitled to carry over to 1971 any portion of its operations losses from 1963 and 1964, which is contingent upon whether the operations loss carryforward was absorbed entirely by petitioner's 1970 life insurance company taxable income. Resolution of the issue depends...
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