MEMORANDUM OPINION
PARR, Judge:
Respondent determined a deficiency of $177,428 in petitioner's Federal income tax for 1994. The issue for decision is whether petitioner sustained a $520,677 loss during 1994, as petitioner asserts, or during 1995, as respondent contends, from the cancellation of various intrastate operating authorities. We hold petitioner sustained the loss during 1994.
Background
This case was submitted fully stipulated...
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