Memorandum Opinion
COHEN, Judge:
Respondent determined a deficiency of $54,758.72 in petitioners' 1979 Federal income tax. After concessions, the issue for decision is to what extent petitioners are entitled to deduct their share of the net operating loss sustained by A & L, Inc., an electing small business corporation, during its taxable year ended October 31, 1979.
Background
Petitioners Jerry L. Shebester (petitioner) and...
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