The respondent determined a deficiency in income tax of the petitioner for the year 1951 in the amount of $2,793.53. The only issue to be decided is whether petitioner is a "purchasing corporation" within the meaning of section 474 (a) of the Internal Revenue Code of 1939. Some of the facts are stipulated. The petitioner filed corporation income tax and excess profits tax returns for the calendar year 1951 with the collector of internal revenue at Columbus, Ohio.
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