OPINION
ROGOSHESKE, Justice.
Taxpayer, Super Valu Stores, Inc., seeks review of a decision of the Tax Court which affirms an order of the commissioner of taxation. The commissioner's order determined that taxpayer was not entitled to an ordinary loss deduction on its 1962 income tax return for the loss sustained upon liquidation of its capital investment in Supercenter, Inc., claimed to be an affiliate corporation. The taxpayer claims that it is entitled...
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