Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined income tax deficiencies of $10,050.71 and $33,146.48 for the calendar years 1936 and 1937, respectively. Petitioner claims overpayments for these years of $291.18 and $2,856.60, respectively.
One issue, for each of the years involved, is upon petitioner's right to a credit in the amount of its entire net income for such year under section 26 (c) (1) of the Revenue Act...
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