OPINION
RAUM, Judge:
The Commissioner determined an income tax deficiency of $722,126 for petitioner's taxable year ending February 29, 1980. At issue is whether petitioner may carry back and claim as part of its consolidated net operating loss deduction for that year a net operating loss incurred by a corporate subsidiary that was an S corporation in the carryback year. The issue arises under the consolidated return regulations issued pursuant to...
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