OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency in the income tax of the petitioner of $27,850.64 for 1951 and one of $29,017.02 for 1952. The issue for decision arises under the Internal Revenue Code of 1939, as amended by the Excess Profits Tax Act of 1950 and the Revenue Act of 1951. It provides for excess profits tax credits for the taxable years based upon the excess profits net income...
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