OPINION
PER CURIAM:
Petitioner appeals a Tax Court decision [reported at 33 T.C.M. 164 (1974)] which found that since his activities during the taxable years 1963-68 did not constitute the "carrying on of a trade or business", he was not entitled to carry over operating losses under section 172 of the Internal Revenue Code of 1954 [26 U.S.C. § 172] or to deduct lobbying expenses pursuant to § 162(e) [26 U.S.C. § 162(e)]. We affirm.
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