DENMAN, Chief Judge.
This is an appeal from a judgment denying appellant a refund of taxes paid by him for the tax year 1945.
The basis of appellant's claim, filed in 1948, is that in the tax year 1947 he suffered a net operating loss which, under 26 U.S.C. §§ 23(s) and 122, as amended, he is entitled to carry back and have deducted from his income of 1945, have the tax for that year recomputed and have a refund of the difference between the tax...
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