OPINION.
JOHNSON, Judge:
This proceeding involves deficiencies of $26,294.05 and $1,517.02 in excess profits tax for the fiscal years ended November 30, 1945, and November 30, 1946, respectively. The issue is whether the petitioner is entitled to include in its equity invested capital under section 718, I. R. C., the sum of $204,775 for distributions in stock made prior to March 1, 1913. All of the facts were stipulated and are so found.
Petitioner...
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