Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Taxable Year Ending Deficiency 5/31/71 ................ $ 46,581 5/31/72 ................ 122,127 5/31/73 ................ 171,721 5/31/74 ................ 55,810
The issues for decision are: (1) whether petitioner's utilization of net operating...
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