Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency in income and victory tax against petitioner for the year 1943 in the amount of $78,748.57. The petitioner claims overpayment in the amount of $7,525.22 or, in the alternative, the amount of $59,313.34 alleged to have been paid within three years before the timely filing of claims for refund for the year 1943. The year 1942 is also involved because of the provisions...
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