Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $155,508.38 in the petitioner's income tax for the fiscal year ended January 31, 1957. The only issue presented for decision is the correctness of the respondent's action in not allowing as deductions in the determination of petitioner's taxable net income for the foregoing taxable year certain net operating losses sustained in fiscal years ended January...
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