T.C. Memo. 1999-291                                  
                               UNITED STATES TAX COURT                                
                    OAK HARBOR FREIGHT LINES, INC., Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 20989-97.                Filed September 1, 1999.           
               Scott A. Schumacher and Darrell D. Hallett, for petitioner.            
               Julie L. Payne, for respondent.                                        
                                 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.            
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