OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $10,851.90 in excess profits tax for 1945. The only issue for decision is whether $86,181.50, representing a credit allowed by the State of New York against the liability of the petitioner for unemployment insurance tax, represents abnormal net income attributable in part to prior years under section 721. The facts are found as stipulated and shown in exhibits.
The petitioner...
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