Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined a deficiency in petitioner's income tax for 1961 in the amount of $51,143.64. The only issue is whether petitioner's deduction in 1961 for net operating losses incurred in prior years should be disallowed because of the provisions of section 269 of the 1954 I. R. C.
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