Memorandum Opinion
OPPER, Judge:
This proceeding seeks a redetermination of deficiencies in petitioner's income and excess-profits tax for the years 1938 and 1939 as follows:
1938 1939 Income ................ $737.74 $733.13 Excess-profits ........ 94.12 48.00
The sole question is whether petitioner is entitled to exhaustion in each of...
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