This proceeding involves an income tax deficiency of $1,754.89 for the calendar year 1943. The sole issue is whether petitioner is entitled under section 23 (s) of the Internal Revenue Code to a net operating loss deduction computed under section 122 of the Code. This depends upon whether it sustained a net operating loss in 1945, as defined by section 122 (a), which it is entitled to carry back and apply against 1943 income under section 122 (b) (1) of the Code. Respondent...
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