WELLS, Judge:
Respondent determined a deficiency in petitioner Intermet Corp.'s (Intermet) Federal income tax in the amount of $615,019 for 1984. The deficiency arose out of respondent's disallowance of Intermet's specified liability loss carryback from 1992 to 1984. After concessions by petitioner, the issues to be decided are: (1) Whether, for purposes of the 10-year carryback provided in section 172(b)(1)(C), certain expenditures incurred by Lynchburg Foundry...
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