Respondent has determined a deficiency in petitioner's excess profits tax for the calendar year 1945 in the amount of $36,377.35.
The only adjustment set forth in the deficiency notice which is disputed is respondent's determination that the entire title insurance premiums reported by the petitioner were earned and that petitioner improperly deducted therefrom "unearned premiums" in the amount of $46,889.63.
The proceeding has been submitted upon the pleadings...
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