Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $469.19 in income tax of the petitioners for 1947, and for 1950 a deficiency of $4,997.12, plus an addition under section 293(a) of $249.86 for negligence. The issues for decision are:
(1) Whether the petitioners are entitled to deduct $1,679.77 in 1949, in addition to the amount allowed by the Commissioner, in determining a net operating loss carryback from 1949 to 1947...
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