MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners petitioned the Court to redetermine deficiencies of $31,962 and $6,647 in their 1998 and 1999 Federal income taxes, respectively. Following concessions, we decide whether petitioners may deduct for those years net operating losses (NOLs) which purportedly arose in earlier years. We hold they may not. Unless otherwise stated, section references are to the applicable versions of the Internal...
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