RIVES, Circuit Judge.
The Tax Court decided that there are deficiencies in income tax for the taxable years 1945 and 1946 in the respective amounts of $42,967.50 and $38.391.44. Those deficiencies resulted from the Tax Court's determination of the net operating loss sustained by the taxpayer during the year 1947 available to him as a carry-back to the years 1945 and 1946 under Section 122 of the Internal Revenue Code of 1939. The pertinent parts of that section and...
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