Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined an income tax deficiency of $81,192 for the taxable year ended June 30, 1973, against Standard Commodities Import and Export Corporation (hereinafter referred to as "Standard" or "petitioner"). The deficiency stems from a $229,150 reduction in petitioner's net operating loss for the taxable year ended June 30, 1975, which in turn reduced a claimed net operating loss deduction...
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