Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies in petitioners' income tax of $33,619.20 for 1973 and $5,905.36 for 1974. Due to concessions by petitioners, the sole issue remaining for decision is whether petitioners' deductible share of the 1973 net operating loss incurred by an electing small business corporation exceeds the amount allowed by respondent.
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