Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined a deficiency in petitioner's 1977 Federal income tax in the amount of $1,133,913. The issues for decision are (1) whether petitioner is entitled to a deduction for a loss on worthless stock and if so, in what amount, and (2) if not, or if the loss is in an amount less than $2,970,000, whether petitioner is entitled to carryforwards and carrybacks of investment tax credits and net...
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