Memorandum Opinion
OPPER, Judge:
By this proceeding petitioner challenges respondent's determination of unjust enrichment tax deficiencies of $18,353.90 and $659.52 for the years 1935 and 1936, respectively.
The primary question involved is whether petitioner has established that it had no net income from the sale of its products processed from hogs during the periods in question, within the meaning of section 501 of the Revenue Act of 1936.
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