The respondent denied taxpayer's claims for refund of excess profits taxes under section 721 of the Internal Revenue Code of 1939 for the years 1942 through 1945.
The sole issue presented for our decision is the question whether taxpayer derived net abnormal income of a class specified by section 721 (a) (2) (C) of the 1939 Code during 1942, 1943, 1944, and 1945, attributable to prior years so as to entitle taxpayer to the relief accorded by that section.
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