JOHN W. OLIVER, District Judge.
This is an action for refund of income taxes. In compliance with our pre-trial orders, all facts were stipulated. The net operating loss carryback and carryover provisions of the Internal Revenue Code of 1939 are involved concerning the years, 1946, 1948 and 1949 for a loss suffered in 1947.
The stipulation of parties establishes that in the latter part of 1943 Dr. Faris became interested in a certain mining property located...
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