OPINION.
FORRESTER, Judge:
The respondent has determined a deficiency in petitioners' income tax for the calendar year 1953 in the amount of $3,362.74. All but one of the respondent's adjustments have been settled prior to trial. The sole issue submitted is whether respondent erred in disallowing a net operating loss carryover to the year 1953 in the amount of $14,683.45. This is in turn dependent on whether a loss sustained by petitioners in 1952...
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