LITTLETON, Judge.
The plaintiffs in this suit seek to recover $4,777.67, plus interest, alleged overpayment of joint individual income tax for the calendar year 1944 occasioned by the carry-back of a net operating loss incurred in 1946. The fact of plaintiffs' loss in 1946 is not contested; the issue presented is whether the particular loss claimed as a "carry-back" was "attributable to the operation of a trade or business regularly carried on by the taxpayer" and...
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