TRAIN, Judge:
Respondent disallowed $23,220.32 of petitioner's 1960 expenses, which had been utilized as a net operating loss carryback, and determined deficiencies in income tax for petitioner's taxable years 1958 and 1959 in the respective amounts of $2,473.67 and $4,117.76.
The issue for decision is whether section 268 of the Internal Revenue Code of 1954
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