Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined deficiencies in the income tax of petitioners for the taxable years 1964, 1965, and 1966 in the respective amounts of $112.71, $821.76, and $467.71. The only issue presented by the pleadings is whether respondent has erred in disallowing to petitioners in their joint individual income tax returns the net operating losses of a small business corporation for each of the...
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