OPINION.
DISNEY, Judge:
The respondent determined a deficiency of $583,003.64 in the petitioner's excess profits tax liability for the year 1942. The petitioner claims an overpayment of excess profits tax in the sum of $935,575.38.
Several issues were raised in the pleadings, but all were settled by stipulation except one, viz.: Whether, for purposes of the so-called 80 per cent limitation provided...
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