Memorandum Opinion
ARUNDELL, Judge:
The respondent has determined a deficiency in income tax for the calendar year 1940 in the amount of $72.68. The deficiency resulted from the disallowance of a claimed net operating loss deduction carried forward from the preceding year. The sole question is whether the loss sustained by petitioner in 1939 was attributable to the operation of a trade or business regularly carried on within the meaning of section 122(d...
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