OPINION.
ARUNDELL, Judge:
Respondent determined deficiencies in income and surtaxes for the calendar years 1942 and 1943 in the amounts of $331,198.28 and $303,689.61, respectively. Petitioner claims there are no deficiencies and that it is entitled to a refund in each year. Respondent, on the other hand, has made claim for increased deficiencies under section 272 (e) of the Internal Revenue Code of 1939....
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