Memorandum Findings of Fact and Opinion
WITHEY, Judge:
A deficiency in the income tax of petitioner has been determined for the taxable year 1952 by the Commissioner in the amount of $46,722.19. The petitioner claims an overpayment of $17,772.01 for the taxable year 1952 based upon an asserted loss carryback from the year 1953, a partial disallowance of which and the determination of additional income for the year 1952 have resulted in the Commissioner's...
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