Memorandum Opinion
KÖRNER, Judge:
Respondent determined deficiencies of income tax against petitioner for its calendar years 1977 and 1979 in the respective amounts of $21,280 and $20,206. The primary issue presented for our determination is whether petitioner was capable of having taxable income in the years in question. If the answer to this question is no, then a secondary issue arises regarding petitioner's entitlement to an overpayment, based upon...
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