United States Tax Court October 22, 1964, Docket No. 87769 (Hambuechen v. Commissioner)

lead-opinion

Fay, Judge:

The Commissioner determined deficiencies in petitioners’ income tax, as follows:

Tear Deficiency

1954_ $9,824.42

1955_ 12,763.44

1956_ 6, 544.03

The only issue for decision is whether petitioners incurred a net operating loss in the year 1951, the unused portion of which could be carried forward as a net operating loss carryover to the years 1954, 1955, and 1956.