WILLIAMS, Judge.
The Commissioner of Internal Revenue, upon a final audit and adjustment of plaintiff's income and excess profits tax returns for the years 1919 and 1920, determined overassessments in favor of the plaintiff of $90,636.41 for 1919, and $734,010.65 for the year 1920. The amount of the overassessments, which were overpayments for the years involved, was applied by the Commissioner as statutory credits against deficiency assessments for the years 1919...
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