WILBUR, Judge:
Respondent has determined deficiencies in petitioner's Federal income tax for the taxable years 1968 to 1970, inclusive, in the amounts of $111,995.87, $84,692.83, and $389.20, respectively. Certain issues having been settled, the sole issue for decision is whether the petitioner's post-reorganization net operating loss carryover is reduced under the provisions of section 382(b),
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