Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in petitioner's income taxes for 1951 and 1952 as follows:
Year Deficiency 1951 ............ $800.85 1952 ............ 460.10
The issues for decision are:
1. Whether the respondent is barred from assessing deficiencies for 1951 and 1952 based upon the disallowance of the carryovers of a net operating loss claimed in 1950,...
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