OPINION
DRENNEN, Judge:
Respondent determined deficiencies in petitioner's income tax for the year 1959, and additions to tax under section 6653 (a), I.R.C. 1954, in the amounts of $72,968.17 and $3,648.41, respectively. In his notice of deficiency issued to petitioner, dated March 11, 1963, respondent determined that petitioner was not entitled to a deduction in the amount of $124,503.25 claimed on his return for 1959 as a net operating loss deduction...
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