United States Tax Court May 4, 1987, Docket No. 38021-84 (Affiliated Capital Corp. v. Commissioner)

lead-opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $66,821 in petitioners’ Federal income tax for 1972. The deficiency arises from the partial disallowance of a claimed net operating loss carryback from 1975 to 1972 based on respondent’s determination that petitioners recognized gain in 1975 from the disposition or satisfaction of an installment obligation.