Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the fiscal years ended April 30, 1961 and 1962, in the amounts of $153,696.77 and $110,504.32, respectively.
One of the issues raised by the pleadings was conceded by respondent on brief, leaving for our decision the question of whether petitioner is entitled to deduct in its fiscal years ended April 30, 1961 and 1962, net operating...
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