ATKINS, Judge:
The respondent determined a deficiency in income tax of the petitioners for the year 1952 in the amount of $438.50.
The question presented is whether, in computing, under section 172 of the Internal Revenue Code of 1954, a net operating loss for 1954 which may be carried back to 1952, the respondent correctly held that an amount of $2,000 received by petitioner during 1954 as an installment payment under the General Motors Corporation...
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