Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in excess profits tax of petitioner for the year 1944 in the amount of $113,453.68.
The sole issue presented is whether petitioner is exempt from excess profits tax on income it received in 1944 under a "Conveyance, Royalty Agreement, and Option," dated December 31, 1941, by virtue of the provisions of section 731 of the Internal Revenue Code of 1939.
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