Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in income tax in the amount of $3,423.32 for petitioner's taxable year ended December 31, 1970. In making this determination respondent, for the purpose of ascertaining whether a net operating loss existed for an earlier taxable year which was available to be carried forward to and deducted in 1970, also examined and made adjustments to the income tax returns petitioner...
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