TIETJENS, Judge:
The respondent determined a deficiency of $2,142.41 in income tax for the fiscal year ended September 30, 1950. The petitioner claims an overpayment of $3,280.65. Certain of the respondent's adjustments are not contested. The issues for decision relate to the application of section 459 (c) of the Internal Revenue Code of 1939. They are (1) whether the petitioner is entitled to compute its average base period net income under the provisions...
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