Overly v. Commissioner

Elmer G. Overly and Mary H. Overly v. Commissioner.

Overly v. Commissioner

Docket No. 54870.

United States Tax Court

T.C. Memo 1956-197; 1956 Tax Ct. Memo LEXIS 95; 15 T.C.M. (CCH) 1044; T.C.M. (RIA) 56197;

August 28, 1956

William W. Scott, Jr., Esq., for the petitioners. Phillip O. North, Esq., for the respondent.

MURDOCK

Memorandum Opinion

MURDOCK, Judge: The Commissioner determined a deficiency of $4,396.08 in the petitioners' income tax for 1951. The issue is whether the petitioners are entitled to a net operating loss carry-back deduction from 1952 under sections 23(s), 122(a) and 122(d)(5) of…