Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in petitioner's income tax for the year 1956 in the amount of $284.24. The sole question in issue is whether petitioner is entitled to an operating loss carryback from the year 1959 in the amount of $836.15 to the year 1956 under the terms of section 172 of the Internal Revenue Code of 1954.
Findings of Fact
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