MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners sought redetermination of deficiencies in their Federal income tax for the taxable years ended September 30, 1981 (FY 1981) and September 30, 1982 (FY 1982) in the amounts of $620,347 and $85,612, respectively. The deficiencies are attributable to the carryback of a net operating loss arising from two deductions claimed on petitioners' consolidated return for FY 1984. We must decide: (1) Whether...
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