For the fiscal year ended November 30, 1945, respondent determined a deficiency in income tax in the amount of $2,124.27 and an over-assessment in excess profits tax in the amount of $6,726.89. In making such determination, the respondent refused to allow an unused excess profits credit carryover and carryback based on a constructive average base period net income for the years ended November 30, 1944, and November 30, 1946. The parties have stipulated that the sole issue...
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