SANBORN, Circuit Judge.
The appellant, a North Dakota farmer, engaged exclusively in the business of farming, in the year 1943 sustained a loss of $18,316.99 on a sale of farms and farm machinery used in the operation of his business. Believing that $15,157.65 of this loss constituted a "net operating loss carry-back" within the meaning of § 122 of the Internal Revenue Code, as amended, 26 U.S.C.A.Int.Rev.Code, § 122, and that this "net operating loss carry...
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