Memorandum Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $1,493,182 in petitioner's Federal income tax for the taxable year 1981. The issue before us is whether the portion of a 1984 consolidated net operating loss (NOL) attributable to petitioner's wholly owned subsidiary, Grove Overseas Corporation (Overseas), may be carried back to petitioner's 1981 year with respect to which petitioner filed a separate return.
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