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OWENS MACHINERY CO. v. COMMISSIONER

Docket No. 1365-68.

54 T.C. 877 (1970)

OWENS MACHINERY COMPANY, INC. (FORMERLY LEARY & OWENS MACHINERY COMPANY, INC.), PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 28, 1970.

Attorney(s) appearing for the Case

Bishop N. Barron, for the petitioner.

Robert D. Hoffman, for the respondent.

OPINION

QUEALY, Judge:

Respondent determined a deficiency in the Federal income tax of Owens Machinery Co., Inc., for the calendar year 1958 in the amount of $1,874.50. The petitioner claims an overpayment for such year in the amount of $36,017.60 resulting from the carryback of a net operating loss deduction for the calendar year 1961. The sole issue relates to a determination of the amount of loss sustained in the calendar year 1961 on account of...

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