The Commissioner determined deficiencies in income tax for 1950 and 1952 in the amounts of $1,175.10 and $8,975.34, respectively. Some of the determinations are not contested. The Commissioner has determined that petitioners are not entitled, under section 122, 1939 Code, to a "net operating loss" carryback from 1951 to 1950, or to a carryover to 1952. The issue is whether a loss sustained in 1951, in the amount of $57,655.40, constitutes a "net operating loss" within the...
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