DRENNEN, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable years 1958 and 1959 in the respective amounts of $34,416.70 and $16,127.37.
The only issue for decision is whether petitioner, all of whose issued and outstanding stock was acquired by Baxter H. Taylor and Sam H. Bushnell in December 1957, is entitled to net operating loss deductions in 1958 and 1959 comprised of net operating loss carryovers from years prior...
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