Memorandum Opinion
STERRETT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1971 and 1972 in the respective amounts of $25,442.03 and $102,421.62.
Due to concessions by the parties, the sole issue for decision is whether petitioners, noncorporate taxpayers using the "regular" tax method provided by section 1, I.R.C. 1954, must offset net operating loss carrybacks against the sum of the ordinary...
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