OPINION
MURDOCK, Judge:
The respondent determined deficiencies for 1958 and 1959 in the income tax of the petitioner. This case was originally set for trial on January 6, 1964, in Chicago at which time the petitioner was permitted to file an amendment to the petition alleging "that the petitioner had sustained a net operating loss of not less than $1,139,176.11 for the taxable year ended December 31, 1962" and claiming a carryback of "not less than...
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