Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax of Calavo, Inc. for the taxable years ended September 30, 1953 and September 30, 1955, in the respective amounts of $14,834.46 and $10,616.87. The deficiency for the taxable year ended September 30, 1953, results from the respondent's determination that he erroneously allowed the deduction in that year of a tentative net loss carryback of $28,527.82...
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