This proceeding involves a redetermination of income taxes for the taxable years ended September 30, 1939, and September 30, 1940. Respondent has determined a deficiency for the two years in the respectively. amounts of $2,217.39 and $6,490.75. Conversely, petitioner claims it has overpaid each such year's tax by $49.74 and $67.30, respectively. In auditing petitioner's income tax returns for the years 1939 and 1940, respondent advised petitioner that he would disallow a...
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