Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $28,013.05 in the income tax of petitioner and her now deceased husband, Sam Parker Pandolfo, for 1957. The issues for determination are the correctness of the respondent's action (1) in determining that net profit from business was understated by $48,000, (2) in not allowing a loss carryback deduction of $56,561.44 for a net operating loss arising in 1959...
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