Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income tax of $11,960 for fiscal year ended August 31, 1983, and $119,185 for fiscal year ended August 31, 1984. While the asserted deficiencies arise in petitioner's fiscal years 1983 and 1984, due to the generation of operating losses in these years and the application of the carryback/carryforward rules, the resulting deficiencies are for...
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