Memorandum Opinion
WOLFE, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181 and 182.
Petitioner filed her income tax return for 1982 as head of household and reported a net operating loss for that year. Petitioner filed a Form 1045, Application for Tentative Refund, claiming an overpayment for 1979 as a result of the alleged net operating loss in 1982. The application...
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