Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1951 in the amount of $38,862.14. The issue to be decided is whether a certain contract was completed in 1952 or 1953 for purposes of determining whether a net operating loss from the contract is applicable to 1951 as a net operating loss carryback.
Findings of Fact
Some of the facts are stipulated and...
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