GOURLEY, Chief Judge.
This is a corporate income tax proceeding which arises out of the termination of a profit sharing trust in which the taxpayer claims a right to recover from the United States of America overpayment of corporate income tax for the fiscal year of 1950, or in the alternative for the fiscal year 1949.
The question for determination is —
Where a taxpayer made contributions to a profit sharing trust under a profit sharing plan...
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