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KITTLE v. COMMISSIONER

Docket No. 35442.

21 T.C. 79 (1953)

OTIS A. KITTLE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 19, 1953.

Attorney(s) appearing for the Case

Kenneth P. Dillon, Esq., for the petitioner.

Edward H. Boyle, Esq., for the respondent.

Respondent determined a deficiency in the income tax of the petitioner for the calendar year 1945 in the amount of $160.71. The basic issue involved is whether petitioner is entitled to a net operating loss deduction for the calendar year 1945 under sections 23 (s) and 122 of the Internal Revenue Code based on a net operating loss carry-back from the calendar year 1947, and, if so, in what amount. Determination of this basic issue...

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