The respondent has determined deficiencies in petitioner's income tax for 1937 and 1938 in the respective amounts of $5,196.23 and $5,020.72. Petitioner alleges that it has overpaid its 1937 tax by the amount of $65.88 and that it is liable for only $366.75 of the 1938 deficiency.
The only question for decision is whether certain taxes which petitioner paid during the taxable years to the Mexican Government were
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