Memorandum Opinion
WHALEN, Judge:
This case comes before us to resolve a dispute between the parties over their computations made pursuant to Rule 155 of the Tax Court Rules of Practice and Procedure (referred to later as Rule 155). The sole difference between the computations is found in the treatment of certain pre-1970 capital losses. Petitioner claims that such losses reduce his 1982 net capital gain from the amount reported on his return, $35,368.88...
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