Memorandum Findings of Fact and Opinion
BRUCE, Judge:
The respondent determined deficiencies in income taxes of the petitioner for the calendar years 1960 and 1961 in the amounts of $4,115.25 and $729.96, respectively.
The sole issue is whether section 382(a), Internal Revenue Code of 1954, bars the allowance of net operating loss deductions claimed on petitioner's returns.
Some facts are stipulated. It is also stipulated that the findings...
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