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YOUNG v. COMMISSIONER

Docket No. 25203-82.

83 T.C. 831 (1984)

JOHN H. YOUNG AND CAROLYN J. YOUNG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 29, 1984.

Attorney(s) appearing for the Case

Edward D. Urquhart, for the petitioners.

Marion S. Friedman, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $48,722.49 in petitioners' Federal income tax for 1977. Petitioners allege that respondent's determination is erroneous and they claim an overpayment of $23,191 in their income tax for the same year. The parties have stipulated that petitioners incurred a net operating loss in the amount of $223,964 for 1976. The only issue for decision is whether

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