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ROSENBERG v. COMMISSIONER

Docket No. 12777-88.

96 T.C. 451 (1991)

ALEX ROSENBERG AND BERTHA ROSENBERG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 7, 1991.

Attorney(s) appearing for the Case

Jay H. Grant, for the petitioners.

Marilyn Devin and Marlene A. Kristovich, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1984 in the amount of $151,238. The issue for decision is whether a net operating loss carryover generated by a subchapter C corporation1 in earlier years may offset income in a later year, at which time a subchapter S election is in effect for the same corporation.

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