Memorandum Findings of Fact and Opinion
SWIFT, Judge:
By way of a statutory notice of deficiency dated February 8, 1980, respondent determined deficiencies in petitioner's Federal income tax liability in the following amounts:
Year Deficiency 1974 .......... $1,210.00 1975 .......... 660.00 1976 .......... 9,371.00
The deficiency determinations for 1974 and 1975 were based on the disallowance of a net operating...
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