PIERCE, Judge:
The respondent determined a deficiency of $33,290.61 in the income tax of the petitioner, Ambassador Hotel Company of Los Angeles, for its taxable year ended January 31, 1944.
Said deficiency is based on the increase in petitioner's income tax as previously returned and determined, which increase resulted, by operation of the applicable statutes, from the adjustment of petitioner's related excess profits tax for the same taxable year...
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