TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable years ended February 28, 1959, and February 29, 1960, and the taxable period March 1, 1960, to December 31, 1960, in the amounts of $247,870.91, $399,861.84, and $245,540.69, respectively. The essential issue involved is the extent to which petitioner should be permitted to carry back its 1961 net operating loss as an offset against prior earnings of its predecessor...
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