IRWIN, Judge:
Respondent determined a deficiency of $9,450.16 in petitioners' income tax for the calendar year 1962. Certain questions having been resolved by the parties, the sole issue presented is whether, in computing their personal income tax, petitioners are entitled to take as a deduction that part of the net operating loss of a small business corporation which exceeds $4,200 — the amount allowed by respondent.
FINDINGS OF FACT
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